- 2 - redetermine these determinations, and these cases were consolidated for trial, briefing, and opinion. Following respondent's concession as to the section 6662 accuracy-related penalty for 1992, we must decide: (1) Whether petitioners' sponsorship of Constant DeMattia's (Constant) golf pursuit was an activity not engaged in for profit within the meaning of section 183(a); and (2) if the activity was one engaged in for profit, whether certain deductions disallowed by respondent are allowable. Unless otherwise stated, section references are to the Internal Revenue Code in effect for the years in issue, Rule references are to the Tax Court Rules of Practice and Procedure, and dollar amounts are rounded to the nearest dollar. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulations of fact and the exhibits submitted therewith are incorporated herein by this reference. Petitioners, husband and wife, resided in Farmington Hills, Michigan, when they petitioned the Court. Petitioners timely filed their joint Federal income tax returns for 1992 and 1993. Walter C. DeMattia has four children from previous marriages. Constant is Dr. DeMattia's youngest child and the only child from his marriage to Fernande DeMattia nee Fernande Allain. Elizabeth J. Crouse is Constant's stepmother. Dr. DeMattia and his son Constant have maintained a very closePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011