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petitioner’s activity. Petitioner claims that sustained
profitability could come from a single win at a major tournament,
but he has not conducted any type of break-even analysis or
attempted to discern how much time and money should be invested
and dedicated to the activity to make it profitable. There is no
evidence that petitioner changed meaningfully his operating
methods to adopt new techniques or abandoned unprofitable methods
of conducting the activity that might lead to a profitable
result. Petitioner’s continued losses appear to indicate that a
timeframe for profit is irrelevant. The Court concludes that
petitioner has merely continued a childhood fishing hobby with a
hope that he may, by chance, derive some profit from tournament
bass fishing.
Possession of expertise in the activity by either the
taxpayer or his advisers may indicate a profit motive. Sec.
1.183-2(b)(2), Income Tax Regs. Petitioner began bass fishing as
a child. Notwithstanding his lack of winning a major bass
fishing competition, he received prize money for his performance
in a number of bass fishing tournaments, appeared on ESPN, and
published a fishing article. Additionally, petitioner has
striven to overcome any lack of expertise by consulting with
several successful individuals in the industry about improving
financial returns from the fishing activity. In his free time,
petitioner regularly watches programs on bass fishing, reads
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