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hours per week on the activities of BRVC. Due to the nature of
the activities conducted through BRVC during those years, i.e.,
mostly consulting services, petitioner was able to promote and
conduct the same activities simultaneously with the duties of her
employment.
Although petitioner was employed by SOI during the years at
issue, she devoted most of her free time to developing contacts
useful to the activities of BRVC. Additionally, due to the
nature of petitioner's work with SOI, she was able to utilize her
duties at SOI to enhance the potential success of BRVC. For
example, through SOI, petitioner was able to make many
professional contacts in the world of volleyball and sports
marketing that held the potential for enhancing the operations
and profitability of BRVC.
Respondent contends that petitioner's full-time employment
during various years of BRVC operation, such as with LSU, the
University of Iowa, and SOI, precluded petitioner from devoting
sufficient time to BRVC so that the activity could rise to the
level of a trade or business. The Court disagrees. This Court
has previously recognized the common-sense notion that a taxpayer
may engage in more than one trade or business simultaneously.
See Gestrich v. Commissioner, 74 T.C. 525, 529 (1980), affd.
without published opinion 681 F.2d 805 (3d Cir. 1982); Sherman v.
Commissioner, 16 T.C. 332, 337 (1951). Moreover, this Court has
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