- 4 - Fishing Activities In 1982, petitioner incorporated Billfish, Inc. (Billfish). Billfish elected S corporation status. Billfish purchased an ocean-going yacht, Renegade, for $600,000. Petitioner is an avid ocean fisherman. He particularly enjoys billfish tournaments. Billfish are large ocean fish with large bills, such as blue marlin, black marlin, and sailfish. During 1983, Billfish advertised Renegade’s availability for charter in the New York Times, The San Francisco Examiner, The Chicago Tribune, and the Miami Herald. During 1983, various employees of the entities that were controlled by petitioner were permitted to use the Renegade for one day each. The employees were responsible for their own round trip airfare, food, and miscellaneous items during the trip, although the entity provided lodging. By the years in issue in this case, Renegade was no longer advertised for charter. As of 1986, when petitioner gave an interview to Marlin magazine, Renegade was not often chartered. During that interview, petitioner stated: You have to be in competitive offshore fishing for the sport * * * not the money. What you win could never cover the expenses. That’s just a drop in the bucket! * * * If you’re in tournament fishing for the money, you’ll go broke. * * * * * * *Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011