Wayne Baseball, Inc. - Page 2

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          administrative record, which includes all the facts upon which              
          respondent made the final adverse determination, was submitted to           
          the Court under Rule 217(b)(1).  Unless otherwise indicated, all            
          section references are to the Internal Revenue Code in effect at            
          the time the petition was filed, and all Rule references are to             
          the Tax Court Rules of Practice and Procedure.                              
               Petitioner is a nonprofit Delaware corporation whose                   
          principal activity is the sponsorship of a highly competitive               
          amateur baseball team.  The team plays almost exclusively in                
          Delaware County, Pennsylvania.  Home games are played on a local            
          high school field, and petitioner does not charge admission to              
          spectators who come to watch the games.                                     
               Each year, the team holds a series of spring tryouts from              
          which approximately 25 players are selected to make up the roster           
          for a 40-game season.  The typical player is over the age of 21             
          and either has competed or currently competes at the collegiate             
          baseball level.  The roster also includes several younger players           
          between the ages of 17 and 21.  Each player possesses a high                
          degree of skill in the game of baseball.  At the time the                   
          administrative record was compiled, one younger player was in the           
          process of trying out for the U.S. national baseball team, which            
          competes in the Olympic and Pan-American Games.  Also included on           
          the team are several perennial veteran players who are in their             

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Last modified: May 25, 2011