Ann Jorgensen - Page 18

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          to complete college or university courses.  Petitioner enrolled             
          in the U.C. Extension courses with specific educational                     
          objectives.  She testified that she has not seen classes                    
          available elsewhere offering similar courses of study.  As                  
          evidenced by several Tax Court cases involving teachers enrolling           
          in university courses and studying abroad in order to improve               
          teaching skills, such an expenditure is "normal" for a high                 
          school teacher.  See, e.g., Ford v. Commissioner, supra; Weiman             
          v. Commissioner, T.C. Memo. 1971-92.  Professional educators act            
          on the assumption that further education improves their ability             
          to use their knowledge effectively.  See Ford v. Commissioner,              
          supra at 1306.  Under the particular facts of this case,                    
          petitioner's participation in the U.C. Extension courses resulted           
          in ordinary business expenditures.                                          
               "Necessary" has been construed to mean "appropriate" or                
          "helpful", not "indispensable" or "required".  Id. at 1305-1307.            
          If there are "reasonably evident business ends to be served, and            
          the intention to serve them appears adequately from the record",            
          expenses satisfy the "necessary" requirement.  Manischewitz Co.             
          v. Commissioner, 10 T.C. 1139, 1145 (1948).  As discussed, the              
          U.C. Extension courses improved petitioner's teaching skills.               
          The expenses associated with a teacher's pursuing further                   
          education that develops her understanding of topics which are               
          part of the curriculum she teaches in her classroom, helps her              

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