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does not differ in any significant respect from parental
expenditures considered nondeductible in a number of cases before
this Court, all of which involved either a parent-child
partnership or a parental sponsorship of the child (involving the
sharing of gross proceeds or net profits) relating to the child’s
effort to become a successful professional athlete or performer.
See Bush v. Commissioner, T.C. Memo. 2002-33 (daughter pursuing a
professional career in ballet), affd. 51 Fed. Appx. 442 (4th Cir.
2002); McCarthy v. Commissioner, T.C. Memo. 2000-135 (son
attempting to become professional motocross racer); Demattia v.
Commissioner, T.C. Memo. 1998-87 (son attempting to become a
professional golfer); Nova v. Commissioner, T.C. Memo. 1993-563
(the same); O’Neill v. Commissioner, T.C. Memo. 1985-92 (son
attempting to become a professional tennis player). In each of
those cases, we applied the factors listed in section 1.183-2(b),
Income Tax Regs., and found the parent taxpayer’s expenditures to
be in the nature of personal or family expenses the deduction of
which is prohibited by section 262(a) or limited by section 183.
We find no basis for reaching a different result in this case.
Petitioner did not take an active part in helping to further
Melissa’s career other than to provide financial support. She
made no financial analysis, and she and Melissa had no business
plan. Most of her time and effort was devoted to her store
manager job, first with Mervyn’s and later in the year with the
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