Christopher Joseph Bush and Robin Leigh Pickering - Page 17




                                       - 17 -                                         
          considered a trade or business for purposes of section 162(a).              
          Accordingly, we sustain respondent’s determination that                     
          petitioners are not allowed certain Aspiring Artists Schedule C             
          deductions for the expenses claimed for the year in issue in                
          excess of the gross income reported by the activity.                        
               The Court has considered all other arguments advanced by               
          petitioners, and to the extent not discussed above, has found               
          those arguments to be irrelevant or without merit.                          
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             under Rule 155.                          





























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