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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.
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 their
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Last modified: May 25, 2011