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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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