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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.
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Last modified: May 25, 2011