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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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