Appellants' Reply Brief - Washington State Courts

expenditure was discretionary, but on whether, as the Board reasoned
here, it was a reasonable expenditure in pursuit of the generation of gross
income for the business enterprise. CABR at 6.
Thus, as the Board explained here, what is determinative is
whether the expenditures at issue can reasonably be seen to promote the
business enterprise and contribute to the business receipts. CABR at 6.
As Malang put it herself, expenses incurred were intended to "facilitate
her business." Tr. 11/20/04 Malang at 25. Here, all of the expenditures
that the Board deducted from Malang's gross receipts fit that test.
For instance, on Schedule C of the income tax forms in the record
here, Malang included, inter alia, telephone, internet access, and dues.
Exs. 19'20. In a business where Malang must stay "connected" to the real
estate market, buyers, and sellers, as well as other agents, to be productive
and competitive, these expenditures appear essential to promote her
business and to generate real estate sales. These expenditures appear
therefore "necessary to or primarily furthering" Malang's ability to
generate her gross commissions, and should as the Board concluded,
legitimately be deducted from her gross receipts as a business expense.
CABR at 6-7.
Similarly, other business expenditures like advertising,
transportation costs. meals and entertainment also contribute to Malang's