John E. and Vicki D. Morrissey - Page 12

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          races as a means of gaining exposure for his sponsor, and                   
          otherwise to enter unsanctioned races where he had the best                 
          chance of success and the opportunity to win larger prizes.                 
          Petitioner was successful in making a profit as predicted in the            
          business plan during 1998.  Petitioner was not able to earn a               
          profit as predicted in the business plan, however, during the               
          years at issue, largely because he had lost his sponsorship and             
          was unsuccessful in persuading other local businesses to sponsor            
          him.                                                                        
               When petitioner realized that he was not able to earn a                
          profit on the drag racing activity as predicted in his business             
          plan, he decided to liquidate his business and sell his race car.           
          See Engdahl v. Commissioner, supra at 667; Canale v.                        
          Commissioner, T.C. Memo. 1989-619 (taxpayer’s decision to leave             
          racing because of its unprofitability supported claim of entering           
          racing with a profit objective).  During the years at issue,                
          petitioner decreased the number of races he entered and testified           
          he entered them mainly to market his car.  The separate checking            
          account, specific business plan, budget and expense forecasts,              
          and decision to modify the activity when it became unprofitable             
          support petitioner’s contention that he carried on the drag                 
          racing activity in a businesslike manner during the years at                
          issue.                                                                      
               2.   The Expertise of the Taxpayers or Their Advisers                  
               We next consider petitioner’s expertise (or the expertise of           
          his advisers) in the drag racing activity.  Preparing for the               





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