Busbee, Tommy W. and Pamela L. - Page 2




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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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