William James Courville - Page 8

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               Petitioner has failed to earn any income from his golfing              
          activity since its commencement in 1991.  At trial, petitioner              
          stated that it was unknown to him when he would earn sufficient             
          income as a professional golfer to sustain the expenses from his            
          activity.  Since July 1995, petitioner has been giving golf                 
          lessons as a means of earning income to finance his golfing                 
          activity.  It appears the only reason petitioner has not claimed            
          Schedule C losses since 1991 is that he had no other income                 
          against which he could deduct the expenses of his activity.                 
          Petitioner did not keep regular books and records of his golfing            
          activity.                                                                   
               After considering all of the facts and circumstances, the              
          Court concludes that petitioner failed to carry the burden of               
          establishing that his golfing activity was carried on with the              
          actual and honest objective of making a profit.  See the similar            
          case of Heywood v. Commissioner, T.C. Memo. 1994-575.                       
          Accordingly, respondent is sustained on this issue.                         
               The next issue is whether petitioner is liable for the                 
          penalty under section 6662(a) for negligence or disregard of                
          rules or regulations.  In pertinent part, section 6662 imposes an           
          accuracy-related penalty equal to 20 percent of the portion of an           
          underpayment of tax that is attributable to negligence or                   
          disregard of rules or regulations.  Sec. 6662(a), (c).  Section             
          6662(c) defines "negligence" as including any failure to make a             





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