James R. and Myrtice L. Peacock - Page 8

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          of team members to that of a smiling, celebratory group of                  
          individuals who shared in the spirit of competition and the                 
          pursuit of the team’s goal to catch the desired fish.  Sometimes,           
          celebrations aboard the yacht included the consumption of                   
          alcohol.  Other times, the captain’s wife accompanied him aboard            
          the yacht, and they and petitioners (and possibly other                     
          individuals) dined aboard the yacht on fish caught during the               
          day.  Petitioners allowed friends and family members to accompany           
          them aboard the yacht during the tournaments.                               
               Both petitioners are extremely knowledgeable about the                 
          techniques of fishing and are experts in catching a desired fish.           
          Petitioners won the 1993 Bahamas Billfish Championship, Ms.                 
          Peacock won the 1994 World Billfish Series, and Ms. Peacock                 
          placed second in the 1995 World Billfish Series.  Ms. Peacock has           
          caught during her lifetime approximately 75 billfish and has been           
          featured approximately 50 times in various sportfishing                     
          magazines.  On one occasion in 1993, Ms. Peacock caught an                  
          885-pound blue marlin which, at that time, was the second largest           
          fish caught in the Bahamas and which, she claims, is displayed at           
          Ripley’s Believe It or Not in Niagra Falls, New York.                       
               PMSI reported for the relevant years the following income              
          items, total deductions, and ordinary income (loss):                        
          1994      1995      1996       1997                                         
          Tournament winnings       -0-   $123,000  $109,270       -0-                
          Consulting fees           -0-    242,997   249,200       -0-                

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