Theodore Langworthy, Jr. - Page 12

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          for 1989 and 1990.  Respondent now agrees that petitioner is                
          allowed deductions for band advertising expenses in the amounts             
          of $1,416 for 1989 and $1,596 for 1990.  Respondent allowed                 
          petitioner no deduction for amounts allegedly paid to bands that            
          played at the Bullfrog.                                                     
               2.   Race Car Expenses--1987 and 1988                                  
               During 1987 and 1988, petitioner owned a "cadet car"13 that            
          he raced in a novice class on Saturday nights at Stateline                  
          Speedway (speedway).  Petitioner also owned a truck, described              
          below, which he used to tow the race car to and from the                    
          speedway, located in Busti, New York, approximately 4 miles from            
          his home.  The Bullfrog and Arthur R. Gren Co., Inc., a beer                
          distributor, sponsored the race car.  Patrons from the Bullfrog             
          often came out to the speedway to see petitioner race.                      
               On his 1987 and 1988 returns, petitioner claimed Schedule C            
          losses from the operation of his race car.  For 1987, petitioner            
          reported income of $1,965 and claimed expenses of $2,865.  For              
          1988, petitioner reported income of $2,440 and claimed expenses             
          of $2,604.                                                                  
               Petitioner's expenses associated with the race car included:           
          Gasoline, oil, tires, A-frames, ball-joints, spark plugs, spark             
          plug wires, distributor caps, pit entrance fees, paint, and                 

          13   A "cadet car" is a "stock car" which is defined as a racing            
          car having the basic chassis of a commercially produced assembly-           
          line model.  Webster's Third New International Dictionary (1993).           





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