Ruth N. Nelson - Page 22




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          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 30               






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