Richard Jackson Sleeper - Page 5

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          Petitioner claimed a loss in the amount of $10,563 from this                
          activity.  On his 1993 return, petitioner reported gross receipts           
          of $1,350, less deductions in the amount of $14,891, for a loss             
          of $13,541 from this activity.  For 1994, petitioner claimed a              
          loss of $14,329 from tournament fishing resulting from gross                
          receipts in the amount of $2,100, less expenses of $16,429.                 
               In the notice of deficiency, respondent disallowed                     
          petitioner's claimed losses from tournament fishing for each of             
          the years in issue because petitioner had not established that he           
          was involved in the activity for profit, and, thus, the                     
          limitation of section 183 applied.  As a computational result of            
          these adjustments, respondent disallowed a portion of                       
          petitioner's itemized deductions in the amounts of $1,003,                  
          $1,286, and $642 for 1992, 1993, and 1994, respectively.                    
               Respondent's determinations are presumed correct, and                  
          petitioner bears the burden of proving them erroneous.  Rule                
          142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933).  Section              
          183 generally limits allowable deductions attributable to an                
          activity to the extent of gross income from that activity if the            
          taxpayer engages in such activity without the objective of                  
          profit.  Section 183(c) defines an activity not engaged in for              
          profit as "any activity other than one with respect to which                
          deductions are allowable for the taxable year under section 162             
          or under paragraph (1) or (2) of section 212."  Whether                     






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