- 20 - reasonable.4 In the case at hand, isolation of the expense is not necessary to determine the reasonableness of the expense. Whether an expenditure is reasonable is a question of fact. See Commissioner v. Heininger, 320 U.S. 467, 475 (1943); Boser v. Commissioner, supra at 1133; Voigt v. Commissioner, 74 T.C. 82, 89 (1980). The focus of our inquiry is on "the primary purpose of the expenditure as it may be inferred from the totality of the facts concerning the benefits to be achieved, the direct relationship of those benefits to petitioner's business, and the reasonableness of the expenses." Stricker v. Commissioner, supra (citing Love Box Co. v. Commissioner, T.C. Memo. 1985-13, affd. 842 F.2d 1213 (10th Cir. 1988)). As discussed, the course improved petitioner's teaching skills. Given the important purpose served by the skills petitioner developed and the benefit derived from her participation in the courses, the expenses associated with the courses appear to be reasonable. See McCulloch v. Commissioner, supra. None of the expenses incurred appear to be lavish, and the particular courses selected by petitioner served important educational purposes. See id. 4 Petitioner paid $4,140 for the Legendary Greece course and $4,500 for the Southeast Asia course. These amounts include course tuition, lodging, and meals. Petitioner contends that respondent assured her that no breakdown of expenses was necessary. Petitioner, therefore, objects to respondent's raising this issue in brief.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011