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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 career
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