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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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