- 7 - proceedings. Although petitioner personally calculated potential for recovery, he did not possess the background and expertise to lend credibility to such projections. There has been no showing that there was any potential for a recovery that exceeded the expenditures on behalf of the litigant; i.e., that Michelle would be entitled to alimony and or some form of damages that exceeded the amount of expenditures that Michelle and petitioner incurred in the proceedings. Even though there was a written agreement, in substance, petitioner was merely being a good parent and assisting his daughter in her time of need. In addition, petitioners were personally seeking custody of their granddaughter. On this record, we are unable to elevate this arrangement to a profit-seeking activity. Accordingly, we hold that petitioners are not entitled to deduct the $39,274 expended in connection with their daughter’s domestic relations litigation. II. Depreciation FINDINGS OF FACT On July 11, 1982, petitioner purchased a 1982 model, 28-foot mobile home for $36,000, and it was placed on a long-term leased lot on Lake Cherokee in Henderson County, Texas. Petitioners permanently affixed the home to the realty by removing the wheels and axles, placing it on foundation blocks, and securing it with steel straps attached to ground anchors. Petitioners addedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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