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relaxed, fished, took pictures, or conversed on matters of a
personal nature. Roach also participated regularly in the beer
can races, events which were held in the spirit of camaraderie
and which, Roach stated, were the perfect venue for entertaining
clients and prospective clients. The fact that the Centurion was
used in connection with an activity of a type generally
considered to constitute entertainment, amusement, and/or
recreation is seen further from the testimony of Roach himself.
He testified:
Q Mr. Roach, how long have you been sailing?
A Since approximately -- I think probably in 1975
was the first time I was ever on a sailboat.
Q So you enjoy sailing?
A Without a doubt.
Q What do you like about sailing?
* * * * * * *
A I think really the bottom line reason I like
sailing is simply because if I am on the water in the
act of sailing -- not doing anything else, but sailing
-- for me, whatever was bothering me back on shore
drops away. I’ve ridden motorcycles for 30 years.
It’s the same experience. There are some things that I
hope for each of us that gives us some release and
sense of simply being in the moment and leaving the
baggage, whatever it may be, of our daily lives behind
for this particular moment.
We sustain respondent’s disallowance of the disputed
deductions.
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