-18-
We find that Mr. Lamb’s tuna fishing activity was an
activity engaged in for profit within the meaning of section
183(c). Petitioners’ deduction of the losses associated with
this activity is, therefore, not subject to the limitations
imposed by section 183(b). It follows that the penalty
provisions of section 6662(a) do not apply.
Decision will be entered
for petitioners.
6(...continued)
there[,] and I hadn’t seen any fish.”
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