- 14 - agree to some level of continued profit participation by petitioner for some period of time. But, as of 1999, there had been no negotiation, and the subject was not one to which petitioner had given much thought. At best, petitioner, in 1999, had a vague notion that she might retain an interest in the profits of Cool G Records after she had been fully reimbursed for her expenditures. But her obvious indifference to that eventuality while continuing to lay out money in support of Melissa’s career indicates that her financial support of Melissa was motivated by parental affection rather than by the anticipation of economic profit. Petitioner’s support of Melissa, the student and daughter, did not differ in kind from her support of Melissa, the aspiring professional. Based upon the foregoing, we find that petitioner has failed to provide credible evidence that she made her expenditures on behalf of Cool G Records “with the objective of making a profit”, as required by section 183 and by section 1.183-2(a), Income Tax Regs. Assuming arguendo, however, that there had been a meeting of the minds between petitioner and Melissa in 1999 and, under their arrangement, petitioner would be entitled to a 50-percent profit share for some period of time after she had recovered her expenses, the result would be the same. Petitioner’s payment of expenses in furtherance of Melissa’s professional music careerPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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