Christopher Joseph Bush and Robin Leigh Pickering - Page 10

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          188 F.3d 507 (6th Cir. 1999); see also Nova v. Commissioner, T.C.           
          Memo. 1993-563.  Thus, we find that petitioner did not operate              
          Aspiring Artists in a businesslike manner.                                  
               Petitioner spoke with two people who are involved in the               
          dance industry.  It appears, from the record, that petitioner               
          spoke with each of the identified “experts” only once.                      
          Petitioner solicited advice regarding securing auditions for his            
          stepdaughter.  Petitioner testified that one expert advised him             
          to have Jennifer “go to a company class with a major company.               
          And she would be the only person dancing with the whole corps de            
          ballet.”  Petitioner followed this advice.                                  
               Petitioners themselves, however, had no prior dance                    
          experience.  Petitioner states that because his stepdaughter has            
          taken dance classes for more than 10 years Ms. Pickering’s                  
          knowledge and experience over those 10 years qualifies her as an            
          expert.  But petitioner did not seek any advice on how to start             
          or maintain a business as a talent adviser.  Petitioner did not             
          contact any “expert” regarding the standard business practices              
          and economics of running his own talent agency.  See Burger v.              
          Commissioner, 809 F.2d 355, 359 (7th Cir. 1987), affg. T.C. Memo.           
          1985-523.  While petitioners might have had some familiarity with           
          the dance industry, that experience does not translate into the             
          ability to operate a profitable business.  Zidar v. Commissioner,           
          T.C. Memo. 2001-200.  We are not persuaded by the evidence on the           

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