John E. and Vicki D. Morrissey - Page 6

                                         -5-                                          
          his car would appreciate in value.  Petitioner instead focused on           
          keeping his car in as good a condition as possible so that it               
          would retain most of its value.                                             
               Petitioner knew that a substantial sponsor was essential to            
          be profitable in drag racing.  While some sponsors pay small sums           
          of money to racers to display the sponsors’ logos on their cars,            
          petitioner was instead interested in cultivating a mutually                 
          beneficial relationship with a sponsor on a larger scale.                   
          Petitioner successfully secured sponsorship in 1998 by the Sac              
          and Fox Casino (Sac and Fox) of $15,000 for the year.  In                   
          connection with the sponsorship, petitioner purchased a new body            
          for his car and painted Sac and Fox’s logo on the car.                      
               Petitioner performed various duties for Sac and Fox,                   
          including acting as a representative of Sac and Fox at races, car           
          shows, and various other public appearances.  Petitioner met                
          patrons and handed out coupons, flyers, and key chains for Sac              
          and Fox at several public appearances.  Petitioner also                     
          coordinated with the Cameron, Missouri, reserve track to sponsor            
          a race, adding $500 to the purse.  Petitioner promoted this race            
          as the Sac and Fox Casino Quick Eight Race.  At the end of the              
          year, petitioner provided Sac and Fox a detailed race report                
          listing each of the events petitioner attended as a                         
          representative of Sac and Fox, with notations about each event.             
          This report indicates petitioner undertook some activity on                 
          behalf of Sac and Fox on 31 days during 1998.  Despite                      
          petitioner’s efforts on behalf of Sac and Fox in 1998, Sac and              





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