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NOTES 861 Tax Lawyer, Vol. 54, No. 4 NOTE THAT’S ENTERTAINMENT: THE SECTION 274(n) DISALLOWANCE FOR ENTERTAINMENT EXPENSES IS HELD TO APPLY TO THOSE IN THE ENTERTAINMENT BUSINESS IN CHURCHILL DOWNS, INC. V. COMMISSIONER In Churchill Downs, Inc. v. Commissioner,1 the Tax Court held that, although Churchill Downs, Inc. (the “taxpayer”) was in the entertainment business, the costs incurred in hosting non-public events leading up to the Kentucky Derby and Breeder’s Cup races, as well as other...