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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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