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pleasure or recreation are involved. Sec. 1.183-2(b), Income Tax
Regs.
The balance of the relevant factors tends to support
respondent's position that petitioner did not engage in
tournament fishing for profit. Petitioner maintained some
records; however, he has not suggested or shown that he did so in
order to conduct his activity in a more profitable manner.
Although petitioner was gaining expertise in fishing over the
years, when he commenced the activity he was a recreational
fishermen, and he did not consult with any advisers, at any time,
concerning the profitability associated with this type of
activity. Petitioner never earned a profit from tournament
fishing, nor could he project when he might do so. Furthermore,
the losses claimed by petitioner in the years in issue produced a
tax benefit by reducing his income tax liability in each year.
Finally, petitioner derived personal pleasure from this activity.
He testified that he chose to compete in bass tournaments, as
opposed to those for other types of fish, because bass are tough
and he enjoys challenges.
On the other hand, some evidence favors petitioner.
Petitioner devoted a significant amount of his free time to
practicing for, and participating in, tournament fishing. In
addition, petitioner worked at securing corporate sponsorship.
However, this effort does not appear to have been directed at
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