Warren R. Follum - Page 4
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During 1990 through 1993, petitioner had people accompany
him when he went fishing because it took two people to run the
boat: One to steer and one to operate the fishing tackle.
Petitioner did not pay the people who accompanied him on his
fishing trips, but he agreed to pay them 10 percent of any
Petitioner did not obtain corporate sponsors for his fishing
activity. Petitioner did not speak at any seminars about fishing
or write any articles about fishing.
Petitioner did not maintain a separate bank account for his
fishing activity. Petitioner did not try to reduce his fishing
During the fishing season, petitioner spent 30 to 40 hours
per week fishing, and, during the off-season, petitioner spent
approximately 10 hours per week on fishing-related activities.
On July 13, 1992, respondent mailed to petitioner a letter
informing petitioner that his 1991 income tax return had been
selected for examination and setting an appointment for
August 7, 1992. By letter dated July 15, 1992, respondent’s
agent rescheduled the appointment to September 11, 1992.
At the September 11, 1992, meeting between petitioner and
respondent’s agent, respondent’s agent provided petitioner with
a Form 4564, Information Document Request, on which respondent
requested petitioner to provide by September 28, 1992, copies of
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Last modified: November 10, 2007