- 2 - The issues for decision are: (1) Whether, for 1992 and 1993, an activity conducted by petitioner known as the Baton Rouge Volleyball Club constituted an activity not engaged in for profit under section 183(a), and, if so, (2) whether petitioner is liable for the accuracy-related penalty under section 6662(a) for negligence or disregard of rules or regulations for each of the years at issue. An ancillary issue is whether, for the year 1993, respondent's computational adjustment to petitioner's State income tax refund is correct. Background In 1970, petitioner received a bachelor of arts degree in physical education and psychology from the University of Northern Colorado. Petitioner's particular focus in physical education is with the sport of volleyball. Petitioner participated in women's volleyball while in college. She was a member of the U.S. Women's National Volleyball Team during the early 1970's. In 1973, petitioner received a master of science degree in physical education from George Williams College in Downers Grove, Illinois. Also, from 1970 through 1972, petitioner served as head coach of the women's volleyball team, head coach of the men's tennis team, and physical education instructor at George 1(...continued) the Internal Revenue Code in effect for the years at issue. All Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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