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is no evidence that petitioner had any expertise in winning
tournaments or translating tournament wins into a profitable
activity. The expertise, research, and study factor favors
respondent.
The fact that the taxpayer devotes much of his personal time
and effort to carrying on an activity, particularly if the
activity does not have substantial personal or recreational
aspects, may indicate an intention to derive a profit. Sec.
1.183-2(b)(3), Income Tax Regs. Petitioner spent weekends and
vacation time during the months of June through September
fishing. The fact that the tournaments were conducted over the
weekends suggests that those conducting the tournaments viewed
the tournaments as primarily a weekend activity. Although
petitioner spent a considerable amount of time fishing, the fact
that petitioner limited his fishing primarily to weekends and
that he fished only during a 4-month span suggests that he did
not undertake the activity to make a profit. Additionally, the
activity has substantial recreational aspects. The personal time
and effort factor suggests that petitioner fished for
recreational purposes and without the intent to make a profit.
An expectation that assets used in the activity may
appreciate may be an indication of a profit objective.
Engdahl v. Commissioner, 72 T.C. 659, 668 (1979); sec. 1.183-
2(b)(4), Income Tax Regs. Petitioner claims his boat
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