- 22 - indicated petitioner's ability and desire to derive a profit from her BRVC activity. The third factor is the time and effort expended by petitioner on the activities of BRVC. During the first several years of operation, petitioner spent at least 20 hours per week conducting the activities of BRVC such as developing camps, clinics, and membership programs and attending speaking engagements, while simultaneously coaching and recruiting athletes for LSU. It was possible for petitioner to devote this amount of time to BRVC because much of the camp, clinic, and tournament activity was conducted on weekends and during summers. Likewise, many of petitioner's speaking engagements and consulting activities conducted through BRVC were performed during the evenings and on weekends. Moreover, petitioner's employment at LSU benefited BRVC in that petitioner was allowed to use the school's facilities to conduct many activities, including camps and clinics, thus saving BRVC the expense of renting appropriate facilities. Rather than hindering the operations of BRVC, petitioner's employment at LSU proved complementary thereto. From 1986 through 1988, petitioner devoted nearly all of her time to BRVC, and the substantial majority of her income in those years was derived from this activity. During her years in Iowa, i.e., 1989 through 1991, petitioner devoted at least 20 to 30Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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