Warren R. Follum - Page 22




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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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