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professional lives. Human nature guides us to choose a hobby
that provides us with a mental and physical respite from the
rigors of a career. In this case, BRVC did not provide
petitioner a respite from her career but, rather, was essentially
an extension and potential augmentation of her professional life
as a volleyball player and coach. BRVC did not allow petitioner
to escape from her professional life, rather, the two appear to
have been intertwined. This factor does not weigh against a
profit motive on the part of petitioner.
The Court acknowledges that this case presents a very close
question, one in which each factor had to be carefully
scrutinized and balanced in order to arrive at the ultimate
conclusion. However, upon considering each of the underlying
facts in this case in the aggregate and evaluating each of the
nine factors giving greater weight to some than others, the Court
believes that the scale tips in favor of a profit motive on
behalf of petitioner.
Therefore, on this record, the Court holds that petitioner
has sustained her burden of establishing that she had an actual
and honest objective of making a profit in her BRVC activity.
Accordingly, the Court holds that BRVC, for 1992 and 1993, did
not constitute an activity not engaged in for profit under
section 183(a). Thus, petitioner is entitled to deduct the
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