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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.
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