The Tax Court yesterday held that the taxpayer’s participation in bass fishing tournaments was an activity not engaged in for profit within the meaning of § 183.  Hill v. Commissioner, T.C. Summ. Op. 2006-120:

[Petitioner] participated in bass fishing tournaments on weekends through the year in issue. He placed in several tournaments, qualified for the Red Man All American in 1997, and received some prize money for his efforts. Petitioner also started a Web site (thebassschool.com) as a means of generating income by offering personal guidance to fishermen; however, this project was abandoned when the site failed to receive any hits…..

After considering the potential payout associated with winning a major bass fishing tournament, petitioner decided, after consulting with his accountant, that he had devoted sufficient time, effort, and attention in traveling to and participating in competitive bass fishing that he was engaged in a trade or business activity….

Petitioner spends 60 to 70 days a year fishing, occasionally taking time from his employment …to compete in one of the 10 to 12 fishing tournaments in which he participates annually.