Ann Jorgensen - Page 19

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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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