James R. and Myrtice L. Peacock - Page 5

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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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