Perry H. Kay, Sr. - Page 13

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          musician, (2) were attended by other bands’ members who shared              
          “some different techniques and various things *** that would                
          benefit any professional musician”, and (3) provided exhibits               
          featuring manufacturers and distributors selling professional               
               While petitioner may have attended seminars and engaged in             
          conversations with various individuals about techniques and                 
          equipment at the conventions, we believe that these activities              
          are not “directly connected with or pertaining to” petitioner’s             
          Schedule C business.  Sec. 1.162-1(a), Income Tax Regs.  The fact           
          that petitioner may have derived some incidental or indirect                
          benefit to his business by attending the conventions is not                 
          sufficient to satisfy the requirements of section 162(a).  See              
          Henry v. Commissioner, 36 T.C. 879, 884 (1961).                             
               The registration forms presented by petitioner at trial                
          clearly establish that the conventions were organized by                    
          educational associations for the benefit of music educators.                
               The Texas Music Educators Association Convention Membership            
          Application requested information pertaining to the applicant’s             
          teaching division and level.  On the application, petitioner                
          selected that he taught band at the middle school/junior high               
          school level.                                                               
               Petitioner completed the Texas Bandmasters Association                 
          Convention Registration Form indicating that he was affiliated              

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