- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011