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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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Last modified: May 25, 2011