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$26,560, $8,066, and $19,598. Respondent also determined for
1997 a $24,498 addition to tax under section 6651(a)(1).
Following concessions, we must decide:
1. Whether petitioners’ deep-sea tournament fishing
activity (fishing activity) was an “activity not engaged in for
profit” under section 183. We hold it was.
2. Whether petitioners may deduct a certain bad debt. We
hold they may not.
3. Whether petitioners are liable for the accuracy-related
penalties and the addition to tax. We hold they are.
Unless otherwise indicated, section references are to the
applicable versions of the Internal Revenue Code. Rule
references are to the Tax Court Rules of Practice and Procedure.
Dollar amounts are rounded.
FINDINGS OF FACT1
The parties have stipulated some of the facts. We
incorporate herein by this reference the parties’ stipulation of
facts and the exhibits submitted therewith. We find the
1 The Court directed each party to file an opening brief and
an answering brief, the latter limited to making any objection to
the opposing party’s proposed findings of fact. Petitioners have
not filed an answering brief. We conclude they have conceded
respondent’s proposed findings as correct except to the extent
that their opening brief contains proposed findings inconsistent
therewith. Morgan v. Commissioner, T.C. Memo. 2000-231, affd. 23
Fed. Appx. 813 (9th Cir. 2001); Fankhanel v. Commissioner, T.C.
Memo. 1998-403, affd. without published opinion 205 F.3d 1333
(4th Cir. 2000).
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