William James Courville - Page 4

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          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.                                                          







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