Ann Jorgensen - Page 17

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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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