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possibility constitutes the greater motivation for the activity.
Stasewich v. Commissioner, T.C. Memo. 2001-30 (quoting Burger v.
Commissioner, T.C. Memo. 1985-523, affd. 809 F.2d 355 (7th Cir.
1987)).
Petitioner’s testimony throughout trial consistently refers
to the pride instilled in him by Jennifer’s hard work and
success. He indicated that Jennifer worked especially hard to go
to high school, work, and simultaneously attend VSA. Petitioner
was very pleased that all of his stepdaughter’s hard work paid
off with a contract with NYTB. The vast majority of the Schedule
C expenses claimed for the year in issue were attributable to
Jennifer’s training, attire, and travel for her dance education.
This fact, coupled with the factors enumerated above, indicates
that petitioner did not engage in this activity out of motivation
for profit. Instead, petitioner’s primary motivation was that of
pride and personal gratification. See Whalley v. Commissioner,
T.C. Memo. 1996-533.
It is plain to this Court that petitioner’s primary and
dominant motivation with respect to expenditures for Jennifer’s
ballet training was familial. The record shows that despite not
being an agent or employee of Aspiring Artists, Ms. Pickering
paid for some of Jennifer’s dance expenses. Petitioners wanted
what most parents want for their children, for them to be
successful in their chosen careers. McCarthy v. Commissioner,
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Last modified: May 25, 2011