Warren R. Follum - Page 4




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               During 1990 through 1993, petitioner had people accompany              
          him when he went fishing because it took two people to run the              
          boat:  One to steer and one to operate the fishing tackle.                  
          Petitioner did not pay the people who accompanied him on his                
          fishing trips, but he agreed to pay them 10 percent of any                  
          profits.                                                                    
               Petitioner did not obtain corporate sponsors for his fishing           
          activity.  Petitioner did not speak at any seminars about fishing           
          or write any articles about fishing.                                        
               Petitioner did not maintain a separate bank account for his            
          fishing activity.  Petitioner did not try to reduce his fishing             
          activity expenses.                                                          
               During the fishing season, petitioner spent 30 to 40 hours             
          per week fishing, and, during the off-season, petitioner spent              
          approximately 10 hours per week on fishing-related activities.              
               On July 13, 1992, respondent mailed to petitioner a letter             
          informing petitioner that his 1991 income tax return had been               
          selected for examination and setting an appointment for                     
          August 7, 1992.  By letter dated July 15, 1992, respondent’s                
          agent rescheduled the appointment to September 11, 1992.                    
               At the September 11, 1992, meeting between petitioner and              
          respondent’s agent, respondent’s agent provided petitioner with             
          a Form 4564, Information Document Request, on which respondent              
          requested petitioner to provide by September 28, 1992, copies of            







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