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or loss from his tournament bass fishing activity. His reported
receipts, expenses, and net profit or loss on Schedule C of his
income tax returns for his tournament bass fishing activity from
1997 through 2001 were as follows:
Gross Receipts Expenses Profit or Loss
1997 $1,470 $ 7,729 ($ 6,259)
1998 779 9,571 (8,792)
1999 871 7,550 (6,679)
2000 1,117 8,134 (7,017)
2001 892 11,303 (10,411)
Petitioner spends 60 to 70 days a year fishing, occasionally
taking time from his employment with Grogan’s to compete in one
of the 10 to 12 fishing tournaments in which he participates
annually. In an attempt to limit participation to those
tournaments with the biggest prize payouts, petitioner’s efforts
focus on competing in tournaments operated by the Bass Angler’s
Sportsman’s Society (B.A.S.S.) or FLW Outdoors, Inc. (FLW
Outdoors).3 Most tournaments petitioner attends are in the tri-
State area of Ohio, Kentucky, and Tennessee, thus generally
requiring less than 200 miles of travel each way for these annual
tournaments. Aside from the time spent fishing, petitioner
3With a membership base of more than 500,000 people,
B.A.S.S., a wholly owned subsidiary of ESPN, is the world’s
largest sports fishing organization, sanctioning more than 20,000
tournaments worldwide. FLW Outdoors is the world’s leading
marketer of competitive fishing, and it administers eight
national tournament circuits, including the Wal-Mart FLW Tour.
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