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conjunction with the end of the high school basketball season.
Petitioner would have many more players turn out for the tryouts
than he had spots for on the RBS team. Once selected for RBS,
players were required to pay $300. This fee was for gym rentals,
coaching, and costs associated with the various basketball
tournaments that RBS participated in.
RBS held weekly practices at rented gyms and recreational
centers and schools near petitioner’s home. During the summer
and fall months, RBS would participate in a series of basketball
clinics and tournaments, including a series of tournaments
sponsored by the Amateur Athletic Union (AAU). These tournaments
were held in Illinois, Minnesota, Ohio, Kentucky, Indiana,
Louisiana, and Florida.
Petitioner maintained a checking account for RBS at Mid-
America Bank in Western Springs, Illinois. At a meeting with an
IRS employee held on November 25, 2005, when specifically asked
whether he had a business plan, petitioner replied that he did
not have a business plan for RBS. On May 25, 2006, however,
during a conference with respondent in preparation for trial,
petitioner presented respondent with a three-page document
entitled, “Business Plan for RBS”.
At some time prior to 2000, the first taxable year in issue,
petitioner started a business known as Dynamic Motivational
Resources (DMR). DMR was a motivational speaking enterprise
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Last modified: November 10, 2007