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  5. 893 F.2d 656 (1990)
 

ANTONIDES v. C.I.R.

Nos. 89-2632, 89-2634 and 89-2699.

893 F.2d 656 (1990)

Gary ANTONIDES, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. David SMITH; Mary Diane Smith, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Richard HERDENDORF; Phyllis Herdendorf, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Fourth Circuit.

Decided January 11, 1990.

Attorney(s) appearing for the Case

John J. Mullenholz (Thomas J. O'Rourke, Neill, Mullenholz & Shaw, on brief) for petitioners.

Thomas Richard Lamons (Shirley D. Peterson, Asst. Atty. Gen., Gary R. Allen, and Gilbert S. Rothenberg, Tax Div., Dept. of Justice, on brief) for respondent.

Before CHAPMAN and WILKINS, Circuit Judges, and WINTER, Senior Circuit Judge.

WILKINS, Circuit Judge.

Gary Antonides, David and Mary Diane Smith, and Richard and Phyllis Herdendorf (the taxpayers) appeal the decision of the Tax Court that their yacht chartering venture was an activity not engaged in for profit. I.R.C. § 183 (West Supp.1989). Antonides also appeals the decision of the Tax Court that he is liable for an addition to tax because of a substantial understatement of tax liability. I.R.C. § 6661 (West 1989). We affirm.

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