(reliance by IRS on I.R.C. Sec. 469(h)(2) to treat members of LLCs as automatically limited partners for passive loss purposes misplaced; general tests for material participation apply and petitioners (married couple) determined to have materially participated in charter fishing activity for tax year at issue - petitioners participated more than 100 hours and their participation was not less than the participation of any other individual during tax year; follows prior opinions in Garnett and Thompson).