-3-
thereafter, Mr. Lamb harpooned approximately 50 tuna per year.
From 1958 through 1982, Mr. Lamb also built and sold one or two
fishing boats per year.
In 1982, Mr. Lamb was diagnosed with diabetes. Due to a
decline in his health, Mr. Lamb sold his fishing boat and also
stopped building fishing boats. In 1986, Mr. Lamb suffered a
major heart attack, which left him hospitalized for 2 weeks.
From 1983 through 1987, Mr. Lamb would go out on boats owned
by young fishermen, who sought to learn from Mr. Lamb the skill
of harpooning tuna. Mr. Lamb did not receive any compensation
for his services, nor did he claim any deductions for expenses
from these activities on his Federal income tax returns for these
years.
During this same time, the price of Atlantic bluefin tuna
was rising significantly. The increase was largely attributable
to the increased demand for fresh bluefin tuna from Japan, a
principal consumer of U.S. Atlantic bluefin tuna.2
Due to this significant increase in tuna prices, on January
6, 1988, Mr. Lamb purchased the Lu-Joy, a 35-foot, 300-horsepower
diesel fiberglass vessel, which was originally built in 1986 as a
lobster boat. After purchasing the Lu-Joy, Mr. Lamb had it
2To illustrate, the price of Atlantic bluefin tuna was
approximately 20 cents per pound during the early 1970's. By
1993, the average price for Atlantic bluefin tuna in the United
States was $10.10 per pound, and, in 1994, the price rose to
nearly $11 per pound.
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