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GAP, from which she derived all of her earned income. She had no
music industry expertise, and she had no prior experience in
backing aspiring recording artists. In addition, there is no
evidence that there were any significant assets associated with
Cool G Records that could appreciate in value. Lastly,
petitioner obviously derived a certain amount of personal
pleasure or satisfaction from watching her daughter progress in a
highly competitive industry. Thus, seven of the nine factors
listed in section 1.183-2(b), Income Tax Regs., militate against
a finding that petitioner’s financial support of Melissa and Cool
G Records was undertaken for profit, and the other two factors
are, at best, neutral (as of 1999, the year in which Cool G
Records first became operative, there could be neither
“occasional profits” nor a “history of income or losses”).
3. Conclusion
Petitioner is not entitled to the deductions (loss) claimed
on Schedule C of the 1999 amended return.
II. Schedule A Deductions
A. Burden of Proof
For the reasons stated infra, in section II.B., we find that
petitioner has failed to introduce credible evidence that she is
entitled to deduct her expenditures for clothing required to be
worn by her on the job by her employer, Mervyn’s, and, as
discussed infra, in section II.C., we find that she has failed to
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