- 17 - 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 isPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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