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$138,890 in the first 40 months of her dance career for
petitioner to break even on his investment. See DeMattia v.
Commissioner, supra; Nova v. Commissioner, supra.
Petitioner makes repeated references to the fact that he was
unable to afford to send his stepdaughter to VSA without her
working part-time jobs to help with expenses. Petitioner asserts
that as a result of his financial status this factor necessarily
falls in his favor. We disagree. Pearson v. Commissioner, T.C.
Memo. 1996-66. Petitioners’ income from wages in 1996 was
$21,584. In addition, petitioner received $11,700 in gross
receipts from activities related to his chess company.
Petitioners were by no means wealthy; however, the deductions
with respect to Aspiring Artists reduced their tax liability. In
addition, petitioners benefited from the personal pleasure
involved in watching their daughter grow into a ballerina. Even
if we were to find that this factor supported petitioners’
position, it would not outweigh the other factors.
The existence of personal or recreational elements in an
activity may indicate that the activity is not engaged in for
profit. Where an activity, however, lacks any appeal other than
profit, a profit objective may be indicated. See sec. 1.183-
2(b)(9), Income Tax Regs. Where the possibility of making of
profit is small (given the other factors) and the personal
satisfaction is substantial, it is clear that the latter
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