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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.
* * * * * * *
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