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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 added
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