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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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