Ann Jorgensen - Page 20

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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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