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the taxpayer entered into the activity for profit. For the most
part, we find those cases to involve facts that are materially
distinguishable from the facts at hand. In Feldman v
Commissioner, supra, the taxpayer purchased a boat with a proven
charter record and an established clientele; the taxpayer made no
personal use of the boat; he negotiated a favorable management
agreement, with a guaranteed minimum level of revenue. In
Dickson v. Commissioner, supra, the taxpayer leased the boat to a
charter agency for guaranteed annual payments and made limited
personal use of the boat. In McLarney v. Commissioner, supra,
the taxpayer regularly spent a substantial amount of time and
energy running the business; the taxpayer changed the mode of
operation to increase profitability; his personal use of the boat
was small in comparison to the number of charters. In Zwicky v.
Commissioner, supra, the taxpayer devoted substantial amounts of
time to the charter operation; the taxpayer engaged in numerous
promotional activities to gain charters; the taxpayer made
minimal recreational use of the boat. Slawek v. Commissioner,
supra, most closely resembles the case at hand in that there we
found that (1) the taxpayers made no real investigation of the
charter boat business before undertaking their charter activity,
and (2) they made no projections of income and expenses as a
basis for estimating whether or not the activity could be
profitable. We also found, however, that they advertised in a
national newspaper, the Wall Street Journal, and that they made
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