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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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