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Over time, petitioners successfully recruited new members
for the western region and began to organize and host several
regional tournaments. During the taxable years in issue,
petitioners hosted six annual tournaments with about 30 to 40
couples participating in each tournament.
Petitioner wife also contributed to the fishing activity by
helping her husband recruit members and promote and organize
tournaments, and by maintaining monthly financial and membership
records. Petitioners’ fishing activity financial records
included detailed information on monthly activity expenses,
including lodging and meal expenses. Petitioner wife also
maintained a separate checking account for the fishing activity,
kept lists of western regional membership, and sent out a
tournament newsletter to members and sponsors in an effort to
retain participating members. Petitioners’ efforts to retain and
recruit members are very important to the conduct of the fishing
activity because of the fee structure of CAST.
Petitioners charge an annual couple membership fee in the
amount of $35, of which they keep $3 and forward the remaining
$32 to Mr. Taylor. In addition, petitioners also charge a fee in
the amount of $55 per tournament to member couples who fish in
regional tournaments.4 Petitioners keep $8 of the tournament fee
and forward $11 to Mr. Taylor: $2 as a “cast fee” and $9 to be
4 Tournament fees were later raised to $75 per couple.
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Last modified: May 25, 2011