Christopher Joseph Bush and Robin Leigh Pickering - Page 3

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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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