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incorporated herein by this reference. At the time that the
petition was filed, petitioners resided in Midland, Texas.
Petitioners are husband and wife. References to petitioner are
to Tommy W. Busbee.
The issue to be decided is whether petitioners’ fishing
activity constituted an activity engaged in for profit pursuant
to section 183 for the taxable years in issue.
During the years in issue, petitioner was employed full time
as a safety representative for Parker and Parsley. Petitioner
wife was also employed full time and worked as a receiving and
shipping clerk for Sam’s Club.
In the late 1980's, petitioners began investigating several
bass fishing tournament organizations in order to see whether
hosting bass fishing tournaments was an activity in which they
could earn income for their eventual retirement.1
In the course of their inquiry, petitioners spoke with Tommy
Taylor (Mr. Taylor), the president of the Couples Association of
Sport Tournaments (CAST). CAST, a sole proprietorship operated
by Mr. Taylor, organized and hosted bass fishing tournaments
1 Petitioners first began bass fishing around 1978, and
petitioner has been a member of several recreational bass fishing
organizations over the past several years. He has also served as
the vice president of the High Sky Bass Club and as a board
member of the Permian Basin Black Bass Invitational and of Texas
Black Bass Unlimited.
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