4
During the years in issue, petitioner earned some gross
income from the tournaments in which he participated. However,
petitioner has never earned income in excess of his expenses from
tournament fishing, including years subsequent to those at issue.
Petitioner could not predict when the activity might become
profitable.
At sometime, petitioner acquired a corporate sponsor, Luhr
Jensen, a lure manufacturer. The sponsor did not pay petitioner
any endorsement fees; however, he was allowed to purchase lures
at a discount. Petitioner also participated in some seminars on
behalf of Luhr Jensen. Petitioner's photograph and testimonial
were displayed in an advertisement for a video on how to obtain
corporate sponsorship. However, it is unclear whether this
occurred during or after the years in issue. Moreover, it does
not appear that petitioner received compensation for this
endorsement.
In 1993, petitioner consulted a certified public accountant
with respect to the preparation of his income tax returns. The
accountant informed petitioner that if he were engaged in
tournament fishing for profit, his related expenses would be
deductible.
On Schedule C of his Federal income tax return for 1992,
petitioner reported gross receipts in the amount of $2,835 and
deductions in the amount of $13,398 from tournament fishing.
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