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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, there
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