Thomas and Linda O'Connell - Page 4




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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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