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is not required by the taxpayer's employer may still be ordinary.
See Boser v. Commissioner, supra at 1132; Carlucci v.
Commissioner, 37 T.C. 695 (1962).
Respondent acknowledges that it is a customary practice of
teachers to travel for the sake of professional development, but
respondent argues that petitioner has not established that it is
normal, usual, or customary for teachers to take U.C. Extension
courses involving travel to foreign countries for professional
development. It is not necessary that petitioner establish that
teachers customarily enroll in U.C. Extension courses. See Hill
v. Commissioner, 181 F.2d 906, 908 (4th Cir. 1950), revg. 13 T.C.
291 (1949). In Hill, the Court of Appeals for the Fourth Circuit
found that it was unreasonable to require the taxpayer to show
that the course she pursued in obtaining further education was
the usual method followed by teachers in obtaining renewal of
their teaching certificates. See id. The court found it
sufficient to establish that an expense is ordinary if the
"particular course adopted by the taxpayer is a response that a
reasonable person would normally and naturally make under the
specific circumstances". Id.; see also Sanders v. Commissioner,
T.C. Memo. 1960-61.
Petitioner is expected, as a teacher in the San Francisco
Unified School District, to pursue a program of professional
growth. One of the accepted means of pursuing such a program is
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