- 4 - Petitioner teaches golf 3 days a week. When he is not teaching, and on his days off, petitioner practices and plays golf. On Schedule C, Profit or Loss from Business, filed with his 1991 Federal income tax return, petitioner reported the income and expenses of his golfing activity. He reported gross income of zero and $16,384 expenses. After 1991, petitioner did not file a Schedule C for his golfing activity. Petitioner's explanation for not filing Schedule C's for his golfing activity after 1991 is as follows: "I had no [wage or Schedule C] income, so how could I write off my expenses against no income?" Petitioner has kept no formal books or records. He did keep a sheet titled "Tax Info" that listed his golfing expenses for 1991, but the amount of the expenses claimed on Schedule C does not correspond with the amounts listed on the sheet. Petitioner also kept certain receipts for expenditures relating to his golfing activity. In the notice of deficiency, respondent determined that petitioner was not engaged in his golfing activity for profit within the meaning of section 183 and disallowed the loss for 1991. In the alternative, respondent determined that, if petitioner was engaged in his golfing activity for profit, then the expenses incurred by petitioner constitute start-up costs under section 195.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011