Anthony J. McCarthy - Page 2

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               Respondent determined a deficiency in petitioner's Federal             
          income tax for 1993 in the amount of $3,696.                                
               After a concession by respondent,2 the issue for decision is           
          whether petitioner is entitled to a business loss deduction for             
          amounts paid in connection with his son's motocross racing                  
          activity.                                                                   
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact and attached exhibits are incorporated             
          herein by this reference.  Petitioner resided in New Britain,               
          Connecticut, on the date the petition was filed in this case.               
               Petitioner was employed as a construction worker during                
          1993, specializing in concrete work.  He worked approximately 40            
          hours per week.  Petitioner has three children.  The activity in            
          issue is related to his oldest son, Benjamin.                               
               As early as 1989, at the age of 9, Benjamin showed an                  
          interest in riding motorcycles.  Petitioner believed Benjamin had           
          a special talent for racing far greater than other children his             
          age.  At the end of 1992, when Benjamin was 12 years old, father            
          and son decided that they would devote a substantial amount of              
          their energies to Benjamin's racing activity.                               



          2         Respondent concedes that petitioner has substantiated             
          the amounts of his claimed Schedule C expenses.  Respondent has             
          only disallowed the portion of the expenses that produced the               
          loss in issue.  Therefore, our decision is limited to such                  
          portion.                                                                    




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