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incorporate new materials into her curriculum, and increases her
ability to reach out to her students are "appropriate" and
"helpful" for a high school teacher.
Inherent in the concept of necessary, however, is that an
expenditure must be reasonable in relation to its purpose. See
Boser v. Commissioner, supra at 1133; Stricker v. Commissioner,
supra; McCulloch v. Commissioner, supra. To the extent that an
expense is unreasonable, it is not necessary. See McCulloch v.
Commissioner, supra; Raines v. Commissioner, T.C. Memo. 1983-125.
In such case, only the portion which is reasonable is deductible
under section 162. See United States v. Haskel Engg. & Supply
Co., 380 F.2d 786, 788-789 (9th Cir. 1967); Boser v.
Commissioner, supra at 1133; McCulloch v. Commissioner, supra.
An expenditure may be ordinary and necessary, but at the same
time it may be unreasonable in amount. See United States v.
Haskel Engg. & Supply Co., supra at 788; Stricker v.
Commissioner, supra.
Respondent contends that because petitioner did not isolate
the tuition cost for the courses, it is impossible to determine
whether the cost petitioner incurred for the education itself is
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