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business. The expenses must be directly or proximately related
to the taxpayer's trade or business. Deputy v. du Pont, 308 U.S.
488, 494-495 (1940); sec. 1.162-1, Income Tax Regs. An expense
is considered "ordinary" if commonly or frequently incurred in
the trade or business of the taxpayer. Deputy v. du Pont, supra
at 495-496. An expense is "necessary" if it is one that is
appropriate or helpful in carrying on petitioner's trade or
business. Commissioner v. Heininger, 320 U.S. 467, 475 (1943).
The expense must also be reasonable in amount relative to its
purpose. Cardwell v. Commissioner, T.C. Memo. 1982-453 (citing
United States v. Haskal Engg. & Supply Co., 380 F.2d 786, 788
(9th Cir. 1967)).
An employee's trade or business is earning his compensation,
and generally only those expenses that are related to the
continuation of his employment are deductible. Noland v.
Commissioner, 269 F.2d 108, 111 (4th Cir. 1959), affg. T.C. Memo.
1958-60.
Petitioner has not established through his testimony or by
other evidence that the rental expenses incurred to store his own
"library" were of a type commonly or frequently incurred in
petitioner's trade or business of earning pay as a part-time
temporary junior college professor. Although it is to be
expected that petitioner would keep a certain amount of books,
maps, and other items on hand as aids to teaching geography, it
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