James R. and Myrtice L. Peacock - Page 21

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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              

          the amount of money that could be won there.                                

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