Anthony J. Carino, Jr. and Jill V. Carino - Page 11




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          has incurred no additional losses since 1996 in the activity.               
          However, we cannot agree that those factors, alone or in                    
          combination, outweigh the inherently personal nature of Mr.                 
          Carino’s association with his daughter.                                     
               Mr. Carino relies heavily on his CLE course work in the                
          areas of sports and entertainment law and his alleged                       
          representation of a country music singer and his negotiations               
          with a local football prospect as evidence of his profit motive.            
          However, he has not been paid by either the singer or the                   
          football prospect for his representation, and he has no agreement           
          or understanding in place providing him with a percentage of, or            
          interest in, any future earnings of those parties.                          
               Petitioners’ daughter has enjoyed success as a dancer, and             
          we have no doubt that Mr. Carino helped her achieve that success.           
          However, Mr. Carino’s payment of expenses for the benefit of his            
          daughter’s dancing activity does not differ in any meaningful way           
          from the contributions made by most parents for the benefit of              
          their children.  See Bush v. Commissioner, T.C. Memo. 2002-33;              
          McCarthy v. Commissioner, supra; DeMattia v. Commissioner, T.C.             
          Memo. 1998-87; Nova v. Commissioner, T.C. Memo. 1993-563.                   
               Moreover, we cannot agree that the execution of the                    
          “Personal Management Agreement” by Mr. Carino and his daughter              
          changes Mr. Carino’s relationship with his daughter from parent             
          to manager for profit.  We have previously declined to give such            






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