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Aspiring Artists’ only contract, entered into in October of
1996, was with petitioners’ daughter.1 Despite having entered
into this contract in October of 1996, petitioners deducted
expenses incurred throughout the entire calendar year.
Jennifer was a high school student at Salem High School
(Salem). In addition to the time she spent at Salem, Jennifer
worked three part-time jobs to help support the pursuit of her
ultimate career goal of becoming a successful ballerina. To help
attain her goals Jennifer trained at the Virginia School of the
Arts in Lynchburg (VSA). VSA serves as a training ground for
people hoping to develop careers in the fine arts, particularly
those interested in dance. VSA is an expensive place to receive
an education.
Petitioners shared Jennifer’s hope that one day she would
have a successful career as a ballerina. To support both their
daughter’s and their aspirations, petitioners helped Jennifer in
any way possible. To help save on room and board petitioners had
Jennifer live at their home and commute the 70 miles to and from
VSA six times each week. Petitioners paid for all expenses
related to Jennifer’s commute, including gasoline, oil changes,
service, and repairs. In addition, petitioners paid for
1 Jennifer turned 18 years old in July 1996. Prior to
attaining the age of majority, Jennifer and petitioner had a
tacit agreement that she would, in one manner or another, pay him
back for some of the money he spent supporting her pursuit of a
ballet career.
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