The petitioner, Harold L. Jenkins, was a well-known country music singer who was commonly known by his stage name of "Conway Twitty".

[5] Although he had no assets with which to pay the debentures, Conway decided to repay the investors the amount of their investments with future earnings.

[5] On his 1973 and 1974 Federal income tax returns, Conway deducted these total amounts, $92,892.46 and $3,600, respectively, as ordinary and necessary business expenses under § 162.

679 (1967), a landmark Tax Court case, established a two-part test to determine whether a payment is deductible as ordinary and necessary.

To determine whether the payments were deductible under § 162, the United States Tax Court was required to After a lengthy explanation of how vital personal reputation is to a member of the country music industry, the Court found that Conway's motive in repaying the investors was to protect his personal business reputation.

When it was time to file taxes Conway thought what he would do Was deduct those payments as a business expense Under section one-sixty-two.

Had Conway not repaid the investors His career would have been under cloud, Under the unique facts of this case Held: The deductions are allowed.