Kathleen A. Carr - Page 2

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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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