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Petitioners argue that this factor weighs heavily in their
favor. We disagree. Although petitioners studied tournament
fishing and competitions from the point of view of a contestant,
and were very good fishers at that, they never undertook a basic
investigation of the factors that affected the profitability of
the fishing activity. See Underwood v. Commissioner, T.C. Memo.
1989-625. Petitioners were aware of the large cash prizes which
could be won at the tournaments and believed that they could win
many of those prizes because their skills were superior to those
of other contestants. Petitioners, however, never seriously
studied tournament fishing from a businessperson’s point of view;
e.g., they never researched or solicited advice on the magnitude
of expenses which they were likely to incur in attempting to win
the prizes. In fact, we are unable to find in the record that
petitioners ever performed any meaningful economic study on the
profit potential of tournament fishing.8 See Vallette v.
Commissioner, T.C. Memo. 1996-285. Petitioners’ expertise and
experience in fishing is counterweighed by their lack of
knowledge on the economics of tournament fishing. This factor is
neutral.
8 By contrast, petitioners did solicit advice on the best
way to catch the desired fish and hired a seasoned crew to help
reach that goal. The fact that they solicited such advice and
hired the crew, but never requested advice on the economics of
the fishing activity, reinforces our conclusion that petitioners’
participation in the fishing activity was recreational.
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