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Petitioners counter respondent's argument as follows: (1) Dr.
DeMattia developed a certain level of expertise by, among other
things, spending a significant amount of time reading
publications on golfers and on the psychology of athletes; and
(2) Dr. DeMattia sought out and obtained advice from various
experts in related fields.
We believe that Dr. DeMattia did indeed take steps to
educate himself in matters relating to the sponsorship and
management of a professional athlete. We also believe that
Dr. DeMattia sought out experts for the purpose of increasing his
son's likelihood of entering the professional ranks. What we do
not find credible is that the aforementioned actions were done by
Dr. DeMattia with a bona fide objective of deriving a profit from
the sponsorship activity. We believe that in cultivating
expertise and making use of experts to support his son's golfing
career Dr. DeMattia was acting as a parent would and not to make
a profit for himself. Cf. Nova v. Commissioner, T.C. Memo. 1993-
563. This factor supports respondent's determinations.
3. Time and Effort Spent in Conducting the Activity
The fact that a taxpayer devotes much of his or her personal
time to an activity may indicate a profit intent, especially
where the activity does not involve substantial personal or
recreational aspects. Also, a taxpayer's withdrawal from another
occupation to devote his or her time and effort to an activity
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