Darryl F. Royster - Page 6




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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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