- 14 -
Upon the basis of the record, we find that the totality of
the facts and circumstances indicates that petitioners' fishing
activity was an activity engaged in for profit pursuant to
section 183. Therefore, petitioners' losses attributable to
their fishing activity are not subject to the limitations of
section 183.
To reflect the foregoing,
Decision will be entered
for petitioners.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
Last modified: May 25, 2011