- 15 - Petitioners counter respondent's argument as follows: (1) Dr. DeMattia developed a certain level of expertise by, among other things, spending a significant amount of time reading publications on golfers and on the psychology of athletes; and (2) Dr. DeMattia sought out and obtained advice from various experts in related fields. We believe that Dr. DeMattia did indeed take steps to educate himself in matters relating to the sponsorship and management of a professional athlete. We also believe that Dr. DeMattia sought out experts for the purpose of increasing his son's likelihood of entering the professional ranks. What we do not find credible is that the aforementioned actions were done by Dr. DeMattia with a bona fide objective of deriving a profit from the sponsorship activity. We believe that in cultivating expertise and making use of experts to support his son's golfing career Dr. DeMattia was acting as a parent would and not to make a profit for himself. Cf. Nova v. Commissioner, T.C. Memo. 1993- 563. This factor supports respondent's determinations. 3. Time and Effort Spent in Conducting the Activity The fact that a taxpayer devotes much of his or her personal time to an activity may indicate a profit intent, especially where the activity does not involve substantial personal or recreational aspects. Also, a taxpayer's withdrawal from another occupation to devote his or her time and effort to an activityPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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