Client is a head golf professional at a private golf club in PA. He also has a golf radio show. He runs the golf operation at the club, gives golf lessons, plays in local professional tournaments, plays and travels with members of the club. He is paid a substantial annual salary (>150k) from his club, has a W-2 from radio for about 25k and has lesson and tournament income of about 25k (appears on his Schedule C).
In 2021 he joined a private club in FL where he can play and practice during the winter. He says that he joined so he can practice to keep and improve his skills which are important to maintaining his golf reputation. The better his performance in tournaments and while playing with members and others he believes enhances his reputation, increases the demand for his lessons and improves his radio show's ratings. It also increases his value to his club. He also belongs to a second club in FL as well as to a club nearby to where he works up north.
The one-time initiation fee he paid to join the FL club and the annual dues are quite large. He also pays annual dues to the two other clubs. He argues that they are ordinary and necessary costs of what he does to earn a living.
I feel that there are other ways he could practice and maintain his skills such as going to an indoor simulator or going to a public driving range incurring a much lesser cost. In most cases, private club dues are not deductible. Is there any case to be made that the primary purpose of joining a club down south in the winter contributes to his ability to earn income and is therefore deductible? He maintains that is the purpose. I believe not deductible.
Thanks all. A week to go!
Paul Herman
Herman & Company CPA's, P.C.
13 Westfield Lane
White Plains, NY 10605
Phone (914) 400-0300, Ext 10