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activity. Hans Hammann obviously derived a great deal of
personal pleasure from sailing as evidenced by his desire to
involve his son in the activity shortly after the child's birth.
It is also obvious, based upon the types of expenses
reported on the Schedules C, that sailing can be a financial
burden. With the exceptions of a de minimis amount for
advertising in 1984, and marginal fuel costs, the expenses
incurred by petitioners in connection with the ownership and use
of the Malaguena would have been incurred regardless of the
operation of the charter boat service. Most likely Hans Hammann
was aware of the fixed costs that would be involved in owning,
maintaining, and sailing a boat such as the Malaguena. Given
petitioners' financial status at the time the sailboat was
acquired, he no doubt realized that he would have to offer the
charter boat services in an attempt to subsidize such costs.
Because of the demands of his employment with the union, Hans
Hammann could only devote limited periods of time to the charter
boat service. Considering such time limitations against Hans
Hammann's practice not to offer the Malaguena for charter unless
he was present on the boat, it would appear to be impossible for
the charter boat service to be a profitable operation during the
relevant years. We conclude that the Malaguena was acquired by
petitioners for recreational purposes, albeit with the intent to
offset some of the costs of ownership through the charter boat
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