- 2 - 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. Background 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 theirPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011