- 20 - income and expenses of BRVC. While petitioner's record-keeping procedures may not have been as meticulous as might be desired, they were sufficient to keep an accurate account of BRVC income and expenses. The record reflects that petitioner expended great effort to advertise and promote the camps, clinics, and membership programs for tournament play conducted through BRVC. Indeed, an activity such as BRVC is not likely to generate gross income in excess of $40,000 for 5 or more successive years8 without a concerted effort at promotion. Additionally, through BRVC, petitioner endeavored to develop and market a volleyball shoe, the Ruth Nelson Sideout, in collaboration with Aspri shoe company. Following the bankruptcy of Aspri, petitioner's move to Iowa, a series of health problems, and her beginning realization that camps, clinics, and membership programs were no longer going to provide potential profits for BRVC, petitioner began to focus the activities of BRVC in the direction of consulting services. Later, during the mid-1990's petitioner attempted another transformation of the activities of BRVC by entering into the prepaid telephone card promotion industry. It is clear that petitioner developed a pattern of changing the activities of BRVC 8 Although the record contains no Federal income tax return information for years prior to 1986, the record indicates that BRVC generated gross income of approximately $50,000 for each of the years 1984 and 1985.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011