Anthony J. Carino, Jr. and Jill V. Carino - Page 3




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          taxable year 1996.  The issue for decision is whether petitioners           
          are entitled to deductions for expenses incurred by Mr. Carino in           
          connection with his daughter’s dancing activities.                          
                                     Background                                       
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  At the time of filing the           
          petition, petitioners resided in Leechburg, Pennsylvania.  Mr.              
          Carino is an attorney licensed to practice law in the                       
          Commonwealth of Pennsylvania.  He has established a profitable              
          personal injury litigation practice.2   Mrs. Carino is a school             
          teacher.                                                                    
               As part of Mr. Carino’s continuing legal education                     
          requirements as an attorney, he took courses in the area of                 
          sports and entertainment law, and he has acquired publications,             
          books, and treatises on that subject.  Mr. Carino claims to have            
          represented an aspiring country music singer and claims that he             
          is in the process of negotiating a salary arrangement and                   
          contract with a professional football prospect.  Mr. Carino has             
          earned no income with respect to these individuals, and                     





               2Mr. Carino reported a net profit from his legal profession            
          of $177,422 in 1993, $93,421 in 1994, $197,938 in 1995, $244,216            
          in 1996, $82,964 in 1997, and $358,870 in 1999.                             




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