Your client is Mr$.$ Raymond Beech; a $65$ year$-$old retired auto worker who has always been an avid fisherman $-$ specifically, freshwater fishing. Throughout most of his adult life, Mr$.$ Beech has always possessed a passion for lake fishing as well as river fishing. He always owned a boat since age $16.$

Mr$.$ Beech is married and claims Florida as his home. His spouse is now $61$ years old and she lives in Florida for most of the year due to her health and her acute motion sickness prevents her from riding on the boat for more than $15$ minutes before exhibiting violent health consequences.

He winters there but spends the late spring, summer and fall up in Ohio $($where he maintains a small mobile home$)$; additionally, he owns a home in Pennsylvania $($across from the Ohio border$).$

He retired at age $62$ and since then has owned a $30$ foot Sport$-$Craft Fishmaster boat that he uses for sport fishing in the Great Lakes $-$ specifically, Lake Huron and Lake Erie. He frequently takes friends on fishing excursions for walleye, yellow perch, salmon, trout, and other fish.

Beginning in $2023,$ however, a marina in the western basin of Lake Erie has proposed that he engage in fishing charters wherein the marina will organize the trip, schedule groups, and remit a pre$-$determined per fishing charter payment amount. He is able to dock his boat and avail himself of the marina's facilities and services for a nominal fee. He is still free to use his boat for recreational purposes, bringing out family and friends, when he is not scheduled for a fishing charter.

He has all the required state and federal permits and licenses $($USCG$,$ Ohio, Pennsylvania$)$ due to his recreational use of his boat bringing on passengers. He is one of the most successful and productive charter boat captains and is highly sought after. His nickname is "All Day Ray" because he is determined that passengers onboard his vessel the "Fish Kill" get their full legal fishing limits per species fished.

A national manufacturer of freshwater fishing tackle has approached your client seeking his opinion on a new and improved version of the standard "Dipsy Diver" trolling lure for walleye fishing. He spent one week in April $2023$ fishing with this new model and received a corporate honorarium of $$15,000$ for his efforts.

Recently, however, the amount of time spent and income earned from the Ohio marina has greatly swelled causing him to seek your advice and counsel concerning the tax and legal issues, if any, in his life. He is receiving social security benefits of approximately $$2,800$ per month, a pension from the Ford Motor Company totaling $$55,000$ per year, and other income of approximately $$15,000($interest$/$dividends$/$investment income$).$ His spouse is working part$-$time earning nearly $$30,000$ per year.

Your client is beginning to feel overwhelmed and is seeking your advice and counsel.

Remember, tax planning does NOT exist in a vacuum; there are other collaterally$-$related issues to address as well. One is the legal aspect and legal exposure. You all completed BUAD $202-$ The Legal Environment of Business class $-$ there is a reason why that class is required for all business administration majors $-$ especially accounting and finance options!

You are to prepare a tax memorandum addressing all the issues present with you client.

Be sure your analysis is thorough and comprehensive in scope$-$ remember you are billing this client $$275$ per hour. Your final work product must reflect this!