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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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Last modified: November 10, 2007