Thomas W. and Pamela A. Hill - Page 12

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          literature in magazines, and accesses articles on the Internet to           
          improve his performance in bass fishing tournaments.  Aside from            
          discussions with his accountant about the bass fishing activity,            
          petitioner has never consulted any financial advisers or persons            
          outside the bass fishing industry.  His failure to seek objective           
          advice about the activity is a negative consideration;                      
          nevertheless, his consistent and continued consultation with                
          successful tournament fishermen coupled with his regular study of           
          the bass fishing industry is a positive consideration.                      
               If a taxpayer devotes significant time and effort to an                
          activity, it may indicate that there is a profit objective.  Sec.           
          1.183-2(b)(3), Income Tax Regs.  Although petitioner was not                
          prepared to leave his full-time employment with Grogan’s for an             
          activity that had no guarantee of success, he consistently                  
          devoted free time and energy to the activity.  Since petitioner             
          was working 40 to 45 hours per week in his regular job, he was              
          limited in the time and effort he could spend bass fishing.                 
          During the 26 weeks of the year that he fished, petitioner spent            
          approximately 40 hours per week on the fishing activity.  His               
          time was divided among many different functions, including                  
          studying ways to improve his performance in tournaments, physical           
          conditioning, practice fishing, maintaining his boat and tackle,            
          and actual tournament competition.  The Court believes that                 
          petitioner devoted significant time and effort to the activity.             






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