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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.
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