- 5 - On its tax return, PMSI reported its principal business activity as providing consultation on automobile dealerships, and, during the relevant years, it had a consulting arrangement with approximately three automobile dealerships. For 1994 through 1997, PMSI’s primary activity involved petitioners’ participation in numerous deep-sea fishing tournaments (the tournaments). Petitioners decided together after consulting with other members of their tournament team that they and the team would participate in the tournaments through PMSI. Petitioners have fished recreationally since their childhood and began tournament fishing for pleasure sometime in 1988 or 1989. The tournaments were mostly part of the Billfish (in this case, blue or black marlin) Series, a series of tournaments held throughout the world with contestants representing a wide range of countries. The Billfish Series tournaments generally awarded trophies and cash prizes to the contestants who within an allotted time caught at the tournament one of the four largest billfish and/or the four contestants who within that time caught the most billfish. The total purse of each of the Billfish Series tournaments generally ranged from $100,000 to $2.5 million, and the individual prizes awarded to the contestants generally ranged from $150,000 to $1.2 million. PMSI did not win any cash prizes in 1994 but won two cash prizes in 1997. PMSI won one or two cash prizes in each of 1995 and 1996.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011