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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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