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effect to these types of arrangements in the case of a parent and
child. See, e.g., Nova v. Commissioner, supra.
Mr. Carino admitted at trial that he derived some degree of
personal enjoyment from his involvement in his daughter’s dancing
activities; however, he claims that just because someone enjoys
an activity should not be conclusive with respect to the issue
before us, citing the enjoyment he derives from his legal
practice. The satisfaction Mr. Carino derives from his legal
practice cannot be compared in principle to the satisfaction he
derives in guiding his daughter in her endeavors. With respect
to his daughter’s dancing activities, the personal satisfaction
to Mr. Carino is so substantial in our view that it constitutes
the primary motivation for engaging in the activity, especially
where, as here, the possibility of making a profit is so very
small. See Bush v. Commissioner, supra; Stasewich v.
Commissioner, T.C. Memo. 2001-30; Burger v. Commissioner, T.C.
Memo. 1985-523, affd. 809 F.2d 355 (7th Cir. 1987); sec. 1.183-
2(b)(9), Income Tax Regs.
Mr. Carino is a successful attorney engaged in a profitable
legal practice. Together, he and his wife reported substantial
annual income during the times relevant herein. However, they
also expended considerable amounts in furtherance of their
daughter’s dancing activities. They seek here to offset their
income in 1996 by the expenses Mr. Carino incurred with respect
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