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All of the expenses at issue were incurred in connection
with these showcases or petitioner's business as a talent
manager. We find that the expenses incurred by petitioner both
were "ordinary and necessary" within the meaning of section
162(a) and arose out of the conduct of petitioner's business. In
reaching our decision, we have relied on the testimony of
petitioner, whom we had an opportunity to observe at trial. We
found her testimony to be candid and credible, as well as
supported by the record. Accordingly, petitioner is entitled to
a deduction for the expenses at issue.
To reflect the foregoing resolution of the issues in this
case,
Decision will be
entered under Rule 155.
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Last modified: May 25, 2011