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may indicate a profit motive. Burleson v. Commissioner, T.C.
Memo. 1983-570; sec. 1.183-2(b)(3), Income Tax Regs.
Respondent argues that any direct time and effort spent on
the activity by Dr. DeMattia is indicative of his love and
affection for his son and the sport of golf. In support,
respondent cites Dr. DeMattia's 20-year history of playing the
game of golf and his history of playing the game with his son.
Petitioners argue that Dr. DeMattia's participation level
indicates that he was engaged in the activity for profit.
Dr. DeMattia testified that he spent a substantial amount of
time, in excess of 30 hours a week, acting as his son's agent,
coach, and manager. Among other things, Dr. DeMattia testified:
As Constant's coach, he would accompany his son to tournaments
and lessons, discuss quality of game play, and make suggestions
on how to improve Constant's play; as Constant's manager, he made
Constant's travel arrangements, paid bills, and spent a
significant amount of time reading varied publications which
addressed all aspects of the professional golfer's game.
Petitioners also cite Mr. DeMattia's retirement from his dental
practice as evidence that he entered into the sponsorship
activity with a profit motive. Dr. DeMattia testified that the
sponsorship of his son's golfing activity was a significant
factor in his decision to sell his dental practice.
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