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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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