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The sole issue for decision is whether various Schedule C
expenses were ordinary and necessary in carrying on petitioner's
business as a personal manager.
Some of the facts have been stipulated, and they are so
found. The stipulation of facts, the stipulation of settled
issues, and the attached exhibits are incorporated herein by this
reference. At the time of the filing of the petition, petitioner
resided in Los Angeles, California.
When she was 3 years old, petitioner became involved in the
entertainment industry as an actress with the Broadway touring
company production of "The Sound of Music". In 1985, petitioner
became a talent agent for Emerald Artists Agency (Emerald).2 In
1987, petitioner received a subagent franchise from the Screen
Actors Guild, Inc., which licensed petitioner as a talent agent
and allowed her to work under her own name rather than Emerald's
name. Petitioner was a successful talent agent.
2 A talent agent is a person or corporation who engages in
the occupation of procuring, offering, promising, or attempting
to procure employment or engagements for artists. In addition, a
talent agent may counsel artists in the development of their
professional careers. Cal. Lab. Code sec. 1700.4(a) (West 1989).
To procure employment for artists, the talent agent must obtain a
license from the California Labor Commissioner. Cal. Lab. Code
secs. 1700.4 and 1700.5 (West 1989). For this purpose the term
"artist" includes actors, actresses, radio artists, musical
artists, directors, writers, cinematographers, composers,
lyricists, arrangers, models, or others rendering professional
services in radio, movies, theater, or television. Cal. Lab.
Code sec. 1700.4(b) (West 1989).
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