Kathleen A. Carr - Page 10

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          Tellier, 383 U.S. 687, 689 (1966); Commissioner v. Heininger, 320           
          U.S. 467, 471 (1943); Deputy v. du Pont, 308 U.S. 488, 495-496              
          (1940).  This usually requires that the expenditure bear a                  
          reasonably direct relationship to the taxpayer's trade or                   
          business.  Commissioner v. Heininger, supra at 470; Deputy v. du            
          Pont, supra at 495; Kennelly v. Commissioner, 56 T.C. 936, 941              
          (1971), affd. without published opinion 456 F.2d 1335 (2d Cir.              
          1972); Sholund v. Commissioner, 50 T.C. 503, 508 (1968); sec.               
          1.162-1(a), Income Tax Regs.  The issue of whether the expenses             
          are ordinary and necessary is a question of fact.  Commissioner             
          v. Heininger, supra at 475; Walliser v. Commissioner, 72 T.C.               
          433, 437 (1979).                                                            
               Because the entertainment industry is visual, publicity is             
          extremely important.  As a talent manager, petitioner guided the            
          careers of at least 17 artists.  To get these artists work, and             
          generate income for her business, petitioner organized,                     
          advertised, and put on showcases for directors, producers, and              
          casting people involved in the entertainment industry to                    
          demonstrate the talents of her artists.  Because her artists were           
          lesser known individuals, petitioner put together several                   
          showcases in an effort to get her artists maximum exposure.                 
          Showcases are a common method used by talent managers to get                
          their clients work in the entertainment industry.                           







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