Mediaworks, Inc. - Page 16

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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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