In Hall v. CIR, T.C. Memo. 1998-336, the United States Tax Court considered the taxation of fishing rights-related related income contributed to an IRA. The court held that a deposit of fishing rights-related income into an IRA does not change the character of the funds. Amounts contributed cannot be deducted at the time of contribution and are not taxable upon withdrawal. The amounts earned on the contributions, however, are subject to taxation upon withdrawal.