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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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