Robert T. and Mary F. Gow - Page 44




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          the marketing brochure created by Offsite to highlight the salient            
          amenities of the time-share resort was the mention of an animal               
          trophy collection.  Also revealing is the fact that the other                 
          members of the joint venture were unaware of the acquisition of an            
          animal trophy collection, which is of significance in view of the             
          fact that the joint venture agreement required a majority of the              
          venturers to decide nonroutine matters.                                       
               In acquiring the animal trophy collection, Mr. Gow personally            
          hunted the animals and made numerous trips to Y.O. Ranch and                  
          Alaska.  On several occasions he took his wife along as a traveling           
          companion.  He used a customized handgun and spent many hours                 
          practicing his shooting skills at a range.  He obviously enjoyed              
          hunting.  Although the mere enjoyment of one’s work may not alone             
          transform a work assignment into a hobby, see Sanitary Farms Dairy,           
          Inc. v. Commissioner, 25 T.C. 463, 468 (1955), petitioners’                   
          enjoyment, along with the questionable business purpose, strongly             
          suggests the hunting activities were for Mr. Gow’s personal                   
          benefit.                                                                      
               In viewing the entire record, we are convinced that all                  
          expenditures incurred for the animal trophy collection were                   
          primarily for the personal benefit of petitioners and thus should             
          be treated as a constructive dividend.  In an attempt to convince             
          us otherwise, petitioners cite Sanitary Farms Dairy, Inc., as                 
          support that costs associated with hunting trips can have a                   






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