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produced a single client. Id. at 885. Further, the taxpayer
failed to prove that it was ordinary for people in his profession
to incur such expenses. Id.
While we are mindful that expenses for personal pursuits do
not become deductible expenses simply because they afford
contacts with possible future clients, the situation in this case
is entirely different from the facts in Henry. Petitioner has
proven that her equestrian activities are necessary to her
success as an interior designer. The unique nature of
petitioner’s design business made it an ordinary expense to
partake in equestrian-related activities to achieve the peer
acceptance to attract clients. We have found that petitioner’s
design and equestrian activity is part of an integrated business
plan and that petitioner’s clientele is almost exclusively
derived from her equestrian contacts. Petitioner also offered
corroborating testimony that individuals in service businesses
who use conventional advertising evoke a negative reaction from
the people at the Jockey Club. Respondent’s arguments focus on
petitioner’s means to an end, but neglect the most important fact
of all--petitioner’s plan worked. Her startup business was a
success from the beginning and continues to be successful,
despite a slight loss in 2004. Petitioner has credibly
demonstrated that the measures she takes to build her client base
are both ordinary and necessary.
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