Busbee, Tommy W. and Pamela L. - Page 8




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          directors he supervises in the amount of $4 per member couple per           
          event.10                                                                    
               Petitioners have also expanded the income potential of their           
          fishing activity by constructing a “weigh station” at Lake O.H.             
          Ivie.  Petitioners use the weigh station, a stage constructed on            
          a flatbed trailer, as a place for tournament participants to                
          display fish, receive fishing awards, and have their pictures               
          taken.  Petitioners earn income from the weigh station by selling           
          advertising space to local businesses and by using the weigh                
          station to recruit additional CAST members.                                 
               Petitioners reported the following Schedule C net losses and           
          profits resulting from their involvement in CAST for the taxable            
          years 1993 through 1998:                                                    
                         1993      1994    1995     1996      1997       1998         
          Gross income   $5,065    $19,788    $23,679    $30,559    $26,474    $17,103
          Total expenses  22,148     41,391     37,52528,822     22,243     15,452       
          Net profit or (loss) (17,083)   (21,603)   (13,846)     1,737     4,231      1,651


          Petitioners also claimed Schedule C net loss deductions for the             
          1991 and 1992 taxable years of $10,943 and $16,466, respectively.           
               In a notice of deficiency for the 1993, 1994, and 1995                 
          taxable years, respondent determined that petitioners did not               
          engage in their fishing activity with an actual and honest                  


               10   At the time of trial, petitioner supervised three newly           
          organized regions of CAST, while also acting as director of the             
          western region.                                                             





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