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359 (7th Cir. 1987), affg. T.C. Memo. 1985-523; Connolly v.
Commissioner, T.C. Memo. 1994-218, affd. without published
opinion 58 F.3d 637 (5th Cir. 1995). Nor did petitioners ever
undertake a meaningful effort to make the fishing activity more
profitable. Mr. Peacock is an accomplished and successful
businessperson who for many years has been directly involved with
the requirements of business, including the need to keep complete
and accurate records. As an individual who had the skills
necessary to make his automobile dealerships profitable and
successful, we believe that he was, or should have been,
sufficiently familiar with business practices to allow him to
conduct the fishing activity in a manner evidencing a profit
objective had he had one. Instead, the manner in which he and
Ms. Peacock fished at the tournaments suggests that they were
participating in the tournaments recreationally. See Connolly v.
Commissioner, supra. This factor favors respondent.
ii. Petitioners’ Expertise
A taxpayer’s expertise, research, and study of an activity,
as well as his or her consultation with experts, may be
indicative of a profit intent. Sec. 1.183-2(b)(2), Income Tax
Regs.
7(...continued)
the amount of money that could be won there.
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