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section 6662(a) for negligence or disregard of rules or
regulations for petitioner's 1991 tax year.
The issues for decision are: (1) Whether a golfing activity
of petitioner was an activity not engaged in for profit under
section 183(a), and (2) whether petitioner is liable for the
accuracy-related penalty under section 6662(a).
Some of the facts were stipulated, and those facts, with the
annexed exhibits, are so found and are incorporated herein by
reference. At the time the petition was filed, petitioner's
legal residence was Sunnyvale, California.
Petitioner has had a life-long goal of becoming a
professional golfer. He has been playing golf since he was 13
years old, and has had a "5" handicap since age 20. As an
amateur golfer, petitioner won six of his local club
championships. He did not receive any prize money for winning
these championships.
Petitioner was employed as an optical engineer for over 30
years. When he was laid off by his employer, Lockheed Missiles &
Space, in May 1991 as a result of Department of Defense
downsizing, petitioner decided to exclusively devote his time to
pursuing his goal of becoming a professional golfer. Petitioner
ceased all activities as an amateur golfer.
In order to qualify to participate as a professional in a
Professional Golf Association (PGA) sponsored tournament in
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