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whether petitioner engaged in tournament fishing for profit
during the years in issue.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated by this reference. Petitioner resided in Dallas,
Texas, at the time his petition was filed.
During the years in issue, petitioner was employed full time
by Gourmet Award Foods as a regional sales manager in
Duncanville, Texas. Petitioner received wage income in the
amounts of $54,489, $47,684, and $47,000 in 1992, 1993, and 1994,
respectively. Petitioner also received income from the sale of
assets in each of these years in the amounts of $5,013, $9,102,
and $10,233.
Petitioner became interested in tournament fishing sometime
in 1989 or 1990. He had friends who were involved in the
activity, and he traveled to lakes with them in order to obtain
knowledge about fishing. To learn about tournament fishing,
petitioner met other fishermen at these lakes and watched fishing
programs on television. Petitioner had not engaged in fishing
prior to this time, although he had fished with his father on
occasion when he was younger. Petitioner began to participate in
tournaments, specifically bass tournaments, in 1990 or 1991.
The tournaments in which petitioner fished were conducted
within the State of Texas. Petitioner fished in some circuit
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