Perry H. Kay, Sr. - Page 12




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          expenses related to the New York City Convention, only $333.95 of           
          the total claimed expense remains at issue.  The majority of the            
          remaining expenses was incurred in connection with two other                
          conventions attended by petitioner during 1998.                             
               In February 1998, petitioner attended the Texas Music                  
          Educators Association Convention in San Antonio, Texas.                     
          Petitioner claimed business expenses relating to the convention             
          in the amount of $113.10.                                                   
               In July 1998, petitioner attended the Texas Bandmasters                
          Association Convention in San Antonio, Texas.  Petitioner claimed           
          business expenses relating to the convention in the amount of               
          $155.79.                                                                    
               Respondent asserts that the expenses incurred with respect             
          to both San Antonio, Texas, conventions relate to petitioner’s              
          employment as an assistant band director and not to PK                      
          Production.                                                                 
               At trial, petitioner testified that the claimed expenses               
          relating to the conventions pertained to both PK Production and             
          his employment as a band educator.  However, petitioner failed to           
          allocate the expenses accordingly, claiming the expenses entirely           
          as business expenses on Schedule C.                                         
               Petitioner further testified that the conventions were                 
          related to his Schedule C business because the conventions (1)              
          offered seminars and workshops that benefited petitioner as a               






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