Vanessa K. Bernardo - Page 1

                                 T.C. Memo. 2004-199                                  

                               UNITED STATES TAX COURT                                

                         VANESSA K. BERNARDO, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 16655-02.               Filed August 31, 2004.              

                    During 1999, P and her daughter, M, formed an                     
               unincorporated venture, V, as the vehicle for pursuing                 
               M’s career as a singer and recording artist.  P                        
               provided the financing for the venture.  P and M orally                
               agreed to a 50-50 division of any profits.  P believed                 
               that, under that agreement, her profit participation                   
               would terminate when she had received sufficient profit                
               distributions to fully reimburse her for all                           
               expenditures on behalf of V.  R alleges that P did not                 
               participate in the activities of V for profit.                         
               Therefore, pursuant to sec. 183, I.R.C., R denies that                 
               P is entitled to deduct any of her 1999 expenditures on                
               behalf of V.  R also alleges that P is not entitled to                 
               deduct her 1999 expenditures for (1) clothing that her                 
               employer required her to wear for work or (2) tax                      
               preparation fees that she failed to substantiate.  R                   
               also denies that P is entitled to either a dependency                  
               exemption for M or head of household filing status for                 
               1999.  R also determined that P is subject to the sec.                 
               6662, I.R.C., accuracy-related penalty.                                

Page:   1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011