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the gross proceeds of the sale of the catch to determine the net
proceeds of the voyage. The crew members, including the captain,
were allocated 50 percent of the net proceeds (the crew members’
share), and the boat owner and the captain were allocated 50
percent of the net proceeds. The crew members, including the
captain, shared the crew members’ share equally after subtracting
the crew’s total expenses for food, payments to “lumpers”
(laborers employed to help unload the catch), and other
miscellaneous items. When petitioner worked as captain, he
received a crew member’s share and a percentage of the 50-percent
share allocated to the boat owner and the captain.2
Dapper Fisheries, Inc., and Rowell Fisheries, Inc.,3 issued
Forms 1099-MISC, Miscellaneous Income, to petitioner reflecting
“fishing boat proceeds” of $3,832.23 and $46,653.96 he received
2The settlement sheet for the voyage of the Elizabeth R. on
which petitioner served as captain indicates that his captain’s
share amounted to 15 percent of the boat owner’s and captain’s
50-percent share of the net proceeds, unreduced by expenses for
food, payments to lumpers, and miscellaneous items. Other
settlement sheets maintained for the Elizabeth R. indicate that
petitioner’s crew member’s share for four voyages was charged for
“clothing” and for one voyage was charged for “supplies.”
3Although Dan Barlow and Doug Rowell owned the Enterprise
and Elizabeth R., respectively, Dapper Fisheries, Inc., and
Rowell Fisheries, Inc., were listed as the “payers” on the Forms
1099-MISC, Miscellaneous Income, issued to petitioner. Whether
the fishing boat owner’s shares and payments referred to supra
note 2 and the text were actually received or paid by the boat
owners or the corporations has no bearing on the outcome of this
case.
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Last modified: May 25, 2011