Vanessa K. Bernardo - Page 15

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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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