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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.
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