Thomas W. and Pamela A. Hill - Page 15

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          those tournaments sponsored by B.A.S.S. or FLW Outdoors with the            
          largest prize payouts, petitioner has chosen to limit his                   
          possibilities for income to the most prestigious bass fishing               
          competitions.  The unfortunate, yet foreseeable, result of this             
          self-imposed limitation is that petitioner has never earned a               
          profit from his bass fishing activity, and there is no indication           
          as to when or whether he will ever attain a profit.                         
               A taxpayer’s financial status may imply whether an activity            
          is conducted for profit.  Sec. 1.183-2(b)(8), Income Tax Regs.              
          Petitioners reported wage income for taxable year 2001 of $90,757           
          and $518 in interest income.  Substantial income from other                 
          sources might indicate a tax incentive for incurring expenditures           
          related to a recreational business.  Jackson v. Commissioner, 59            
          T.C. 312, 317 (1972).  While it is unclear that the tournament              
          bass fishing activity was conducted to generate tax savings,                
          petitioners’ income indicates that they possessed sufficient                
          disposable income to sustain such losses each year from the                 
          activity and realize tax savings therefrom.                                 
               Finally, the presence of personal motives may indicate that            
          the activity is not engaged in for profit.  Sec. 1.183-2(b)(9),             
          Income Tax Regs.  Petitioner’s bass fishing activity has allowed            
          him to devote a substantial portion of his spare time to a hobby            
          he has loved since childhood.  Further, the activity has                    
          permitted petitioner to test his fishing skills against other               






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