- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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