Darryl F. Royster - Page 3




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          the years in issue, and all Rule references are to the Tax Court            
          Rules of Practice and Procedure.                                            
               Respondent determined deficiencies of $5,995, $5,060, and              
          $6,089 in petitioner’s Federal income taxes, and accuracy-related           
          penalties under section 6662(a) of $1,199, $1,012, and $1,217.80            
          for taxable years 2000, 2001, and 2002, respectively.  The issues           
          for decision are:  (1) Whether, for the taxable years in issue,             
          an activity conducted by petitioner known as Royster Basketball             
          School constituted an activity engaged in for profit within the             
          meaning of section 183(a); (2) whether petitioner is entitled to            
          deduct expenses relating to Royster Basketball School during the            
          years in issue under either the foregoing section or, in the                
          alternative, section 183(b)(1) and (2); and (3) whether                     
          petitioner is liable for the accuracy-related penalty under                 
          section 6662(a) for negligence or disregard of the rules or                 
          regulations for each of the years at issue.1                                




               1 Two adjustments in the notice of deficiency were not                 
          addressed at trial and are, therefore, deemed conceded. One of              
          these adjustments relates to whether petitioner is liable for               
          self-employment tax stemming from his work as a basketball                  
          referee during the years at issue, and as listed on the Schedules           
          C, Profit or Loss From Business, he attached to his returns for             
          2000, 2001, and 2002. Respondent determined that petitioner is              
          liable for self-employment tax on that income with a                        
          corresponding deduction for one-half of that tax.  The second               
          adjustment that is also deemed conceded relates to unreported               
          income in the amount of $875 received in 2000.                              






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