Warren R. Follum - Page 26




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          says this, coupled with the frequently low air and water                    
          temperatures during tournaments, made every trip very                       
          uncomfortable.  However, petitioner had been fishing for 30 years           
          before entering tournaments.  Presumably, petitioner enjoyed                
          fishing enough to overcome his discomfort when he fished outside            
          of tournaments.  On the basis of the record as a whole, we                  
          conclude that petitioner entered fishing tournaments for                    
          recreation and did not engage in his fishing activity with the              
          primary objective of making a profit.                                       
               Having reviewed the underlying liability de novo, we find no           
          error.  Additionally, we find no error or abuse of discretion by            
          respondent in determining to uphold the filing of the lien                  
          against petitioner.                                                         
               We have considered all of petitioner’s contentions, and to             
          the extent they are not addressed herein, they are irrelevant,              
          moot, or without merit.                                                     
               To reflect the foregoing,                                              

                                                   Decision will be entered           
                                              for respondent.                         














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