Tony L. Zidar and Kathleen I. Zidar - Page 5




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          received $50,000 and forgiveness of his $116,831 indebtedness to            
          CRC.4                                                                       
               For 1992, CRC issued Tony a Form 1099-MISC, Miscellaneous              
          Income (the Form 1099), reporting a $166,831 payment.                       
          Petitioners claim not to have received a copy of the Form 1099.             
          Tony’s Stock Car Activity                                                   
               In the late 1960's, Tony became involved in automobile                 
          racing, first by working on pit crews and later by participating            
          in stock car racing as a hobby.  In the early 1980’s, he and                
          Robert purchased an automobile racetrack located in the city of             
          Oregon, Wisconsin, and ran it for a couple of years.                        
               In 1991, Tony remortgaged his house for $50,000 to finance             
          construction of a stock car for asphalt automobile racing.  His             
          goal was to have a stock car ready for racing in the American               
          Speed Association’s (ASA’s) 1992 racing season.  During 1992,               
          Tony had a stock car (the stock car) built to ASA standards,                
          hiring an Illinois contractor to build a body for the Oldsmobile            
          chassis and a Wisconsin contractor to install the parts.                    




               4  On their 1992 Federal income tax return, petitioners                
          reported a sale price of $800,000 for the joint ventures.                   
          Petitioners reported the transaction as an installment sale,                
          showing that in 1992 they received $699,925 of the total $800,000           
          sale price and that they had realized $73,894 of capital gains in           
          1992 under the installment method.  Respondent has raised no                
          issue regarding petitioners’ income tax reporting of Tony’s sale            
          of his interests in the joint ventures.                                     





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