Walter C Demattia and Elizabeth J. Crouse - Page 15

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          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 activity              





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