Ruth N. Nelson - Page 2




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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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