- 19 - 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 thePage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
Last modified: May 25, 2011