Ruth N. Nelson - Page 19




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          She admitted that she occasionally deposited personal funds into            
          the BRVC checking account when BRVC experienced a negative cash-            
          flow, but this fact does not indicate that petitioner lacked                
          profit motive.  Rather, the Court views this as providing the               
          necessary capital to keep the activity going.                               
               Petitioner also paid some personal expenses out of the BRVC            
          checking account and had some credit cards that she used for both           
          business and personal expenses.  However, through receipts,                 
          canceled checks, and credit card statements, petitioner kept                
          track of which expenses were business as opposed to personal, and           
          petitioner made no attempt to deduct personal expenses for income           
          tax purposes.  Petitioner sought the advice and services of a               
          certified public accountant in the preparation of her Federal               
          income tax returns during the years of BRVC operation.  For the             
          years at issue, no adjustments were made by respondent with                 
          respect to the expenses claimed on the ground that such claimed             
          expenses were personal.                                                     
               Moreover, for approximately the first 10 years of BRVC                 
          operation, petitioner kept ledgers in connection with the                   
          volleyball camps, clinics, and membership programs for tournament           
          play conducted by BRVC.  Petitioner stopped maintaining these               
          ledgers around 1992, subsequent to the cessation of camps,                  
          clinics, and membership programs through BRVC.  After 1992,                 
          petitioner maintained computer records in connection with the               






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