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Background
Some of the facts have been stipulated by the parties and so
found. The stipulation of facts and attached exhibits are
incorporated herein by this reference. At the time the petition
was filed in this case, petitioner resided in Chicago, Illinois.
During the years in issue, petitioner was employed full time
by the Internal Revenue Service (IRS) as a computer equipment
analyst/information technology specialist.
Petitioner has played basketball since adolescence, and
played on the basketball team at McMurray College in
Jacksonville, Illinois. After college, petitioner shifted his
interest from playing basketball to being a basketball referee.
Petitioner has been a high school basketball referee for the past
33 years and has attended referee training programs sponsored by
the National Basketball Association (NBA), as well as the
National Collegiate Athletic Association (NCAA).
During the taxable years in issue, petitioner refereed high
school basketball games. Petitioner filed Schedules C, reporting
income and business expenses pertaining to this activity for each
of the taxable years at issue.
In 1998, petitioner parlayed his involvement with high
school basketball by establishing a traveling men’s basketball
team and skills school known as Royster Basketball School (RBS).
Petitioner’s dual purpose in establishing this team was to
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Last modified: November 10, 2007