Derril O. Lamb, Jr. and Joyce Lamb - Page 15

                                                  -15-                                                    
                  (6)  The Taxpayer’s History of Income and Losses With                                   
            Respect to the Activity, and (7) the Amount of Occasional                                     
            Profits, if any, Which Are Earned                                                             

                  Mr. Lamb reentered the tuna fishing business in 1988, and                               
            this activity generated the following losses:                                                 

            Year               Loss                                                                       
            1988             $22,349                                                                      
            19891                --                                                                       
            1990              21,863                                                                      
            1991              15,053                                                                      
            1992              11,191                                                                      
            1993              11,212                                                                      
            Total          $81,668                                                                        

                  1Mr. Lamb did not conduct any commercial fishing activity                               
            during 1989 or after 1993.                                                                    

                  A record of substantial losses over several years is                                    
            generally indicative of the absence of a profit objective.                                    
            Golanty v. Commissioner, 72 T.C. at 426.  The record indicates                                
            that Mr. Lamb purchased the Lu-Joy and reentered the tuna fishing                             
            business in 1988 with the belief that he “was going to make a                                 
            killing”, given the rising prices for tuna.  The record also                                  
            clearly indicates that Mr. Lamb was an accomplished fisherman                                 
            with many years of experience.  We do not believe that a                                      
            fisherman with Mr. Lamb’s expertise would have caught only one                                
            fish in 2 years if he had been healthy.  Unfortunately, Mr.                                   
            Lamb’s eyesight, which is obviously so vital to a harpoon                                     






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