James R. and Myrtice L. Peacock - Page 28

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          that they both enjoy with a subsidy from the fisc.  This factor             
          favors respondent.                                                          
               ix.  Elements of Personal Pleasure                                     
               Although the mere fact that a taxpayer derives personal                
          pleasure from a particular activity does not mean that he or she            
          lacks a profit intent with respect thereto, the presence of                 
          personal motives may indicate that the activity is not engaged in           
          for profit.  This is especially true where there are recreational           
          elements involved.  Id.  “[T]he fact that the taxpayer derives              
          personal pleasure from engaging in the activity is not sufficient           
          to cause the activity to be classified as not engaged in for                
          profit if the activity is in fact engaged in for profit as                  
          evidenced by other factors”.  Id.                                           
               Petitioners argue that this factor weighs in their favor.              
          We disagree.  Petitioners began tournament fishing for pleasure             
          sometime in the late 1980s and focused their participation in               
          tournaments on ones held in exotic, resortlike locations.                   
          Although a taxpayer’s participation in a tournament fishing                 
          activity may sometimes qualify as an activity engaged in for                
          profit, e.g., Busbee v. Commissioner, T.C. Memo. 2000-182, such             
          is not the case here.  Petitioners’ pursuit of competitive                  
          excellence was not motivated primarily by the pursuit of profit.            
          On the basis of our evaluation of the record as a whole,                    
          including our viewing of an approximately 1-hour video on the               

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