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he was building in RBS, but that he hoped to parlay his
reputation as the director/coach of a basketball skills school
into a “six-figure salary with Nike or Adidas.” This goal,
however, by itself, does not negate the presence of any profit
objective. We do conclude, however, that petitioner’s statements
to this effect illustrate that his intention to make a profit was
not one for RBS, per se, but for himself in the form of a
lucrative contract with a shoe company to work as their talent
scout. While we recognize that petitioner did derive some
personal pleasure in operating RBS, this factor, by itself, does
not negate a lack of profit objective. Accordingly, we view this
factor as neutral.
In summary, petitioner repeatedly testified that he did not
intend to derive a profit from RBS, per se, but had high hopes
that the success of his school would parlay into a personal
opportunity for himself to work for a major athletic shoe or
apparel company. With startling candor, petitioner testified
that he did not take steps to make RBS profitable, as many of his
students could not afford the $300 enrollment fee. While we are
sympathetic to the accommodations petitioner made to the young
players who played for RBS, we cannot look askance at
petitioner’s admissions and the lack of any business plans or
budget projection aimed at making RBS into a profitable
enterprise. Moreover, RBS never made a profit, and the record is
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