Darryl F. Royster - Page 18




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          willingness to follow expert advice may also indicate a profit              
          objective.  Dworshak v. Commissioner, T.C. Memo. 2004-249.                  
               Petitioner has been involved with basketball since he was a            
          teenager.  Petitioner knows of one person that has been hired by            
          an athletic apparel company after running a youth basketball                
          school.  In addition, one of petitioner’s best friends, a former            
          professional basketball player, works as a talent scout for an              
          athletic shoe company and teaches basketball skills.  While                 
          petitioner clearly possesses a personal knowledge about the                 
          business of basketball, his knowledge does not extend to the                
          economics of running a basketball school.                                   
               Petitioner testified that he has neither business experience           
          nor experience in coaching youth basketball.  Petitioner                    
          testified that he began his school only after seeing his friend,            
          a former professional basketball player, garner a highly paid               
          position with an athletic shoe company after sponsoring a youth             
          basketball team.                                                            
               Based on the record, we conclude that although petitioner              
          does have a notable background in basketball–-both as a player              
          and as a referee–-he was not an expert in running a basketball              
          school, and he did not seek out expert advice regarding the                 
          economic realities of running such an endeavor.  The fact that              
          petitioner’s inspiration for starting his basketball school was             
          his friend who was a former professional basketball player                  







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