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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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