5
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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