- 13 -
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
equipment.
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
Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 NextLast modified: May 25, 2011