- 21 - profitability may also indicate a profit motive. Id. Petitioner testified that he conducted a profit and loss analysis relative to his fishing activity. However, petitioner failed to produce the analysis at trial. Petitioner did not produce any fishing activity records at trial and did not maintain a separate checking account for his fishing activity. Additionally, there is no evidence of record to reflect that petitioner used records to evaluate or improve the financial aspects of his fishing activity. The foregoing suggests that petitioner engaged in his fishing activity for recreational purposes. See Peacock v. Commissioner, T.C. Memo. 2002-122. A taxpayer’s expertise, research, and study of an activity, as well as his consultation with experts, may be indicative of a profit motive. Sec. 1.183-2(b)(2), Income Tax Regs. Although petitioner testified that he consulted with fishing experts, there is no evidence in the record to indicate that petitioner ever researched the expense involved in attempting to win the prizes at fishing tournaments. There is also no evidence of record to show that petitioner performed any meaningful study of the factors affecting the profitability of tournament fishing. See Peacock v. Commissioner, supra; Hoy v. Commissioner, T.C. Memo. 1991-575. Petitioner also argues that he had been fishing for over 30 years and “was considered a very good fisherman.” However, therePage: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 NextLast modified: November 10, 2007