Walter C Demattia and Elizabeth J. Crouse - Page 2

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          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 close                  





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