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fisherman’s success on the sea, deteriorated due to his diabetic
retinopathy.
(8) The Financial Status of the Taxpayer
The regulations provide that “Substantial income from
sources other than the activity (particularly if the losses from
the activity generate substantial tax benefits) may indicate that
the activity is not engaged in for profit especially if there are
personal or recreational elements involved.” Sec. 1.183-2(b)(8),
Income Tax Regs. On their 1990 Federal income tax return,
petitioners reported wages from Marriner Lumber and Oregon Bow
totaling $53,074, interest income of $29,653, dividend income of
$686, capital gains of $64,583, and miscellaneous income of
$4,539. On their 1991 return, petitioners reported wages from
Marriner Lumber of $31,772, interest income of $29,454, dividend
income of $557, taxable refunds of State and local income taxes
totaling $1,708, capital gains of $23,398, Schedule E income of
$44,633, and miscellaneous income of $5,331. Petitioners clearly
received a tax benefit from the losses generated by Mr. Lamb’s
tuna fishing activity.
(9) The Presence of Elements of Personal Pleasure or
Recreation
The “fact that the taxpayer derives personal pleasure from
engaging in the activity is not sufficient to cause the activity
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