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years, that business was terminated in 1987. That same year,
petitioner changed careers and began working for Grogan’s
Healthcare Supply, Inc. (Grogan’s), a medical products
distribution company.
Petitioner remained with Grogan’s when he resumed tournament
bass fishing in 1992. He qualified for the American Scholarship
Championship that year. Thereafter, petitioner, while continuing
his employment with Grogan’s, participated in bass fishing
tournaments on weekends through the year in issue. He placed in
several tournaments, qualified for the Red Man All American in
1997, and received some prize money for his efforts. Petitioner
also started a Web site (thebassschool.com) as a means of
generating income by offering personal guidance to fishermen;
however, this project was abandoned when the site failed to
receive any hits.
After considering the potential payout associated with
winning a major bass fishing tournament, petitioner decided,
after consulting with his accountant, that he had devoted
sufficient time, effort, and attention in traveling to and
participating in competitive bass fishing that he was engaged in
a trade or business activity. Beginning in 1997 and continuing
through 2001, the year at issue, petitioner included a Schedule
C, Profit or Loss From Business, with his Federal income tax
return for each year, reporting the income, expenses, and profit
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