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Petitioner conducted research on sponsorship opportunities
and racing strategies. He decided which races Benjamin would
enter and what size motorcycle Benjamin would ride. He performed
any necessary maintenance or repair work on the motorcycles. In
addition to his involvement in Benjamin's racing, petitioner's
experience with motocross racing includes 2 years of his own
amateur racing in 1976 and 1977.
Petitioner purchased a vehicle that he described as his
"race truck". The vehicle has sleeping quarters for four
individuals and is equipped with a refrigerator, microwave,
toilet, shower with running hot water, and television. The
vehicle also has a rear work area where petitioner prepares
Benjamin's motorcycles for the races.
Benjamin entered numerous races and placed well in most of
them. At the time of trial, Benjamin had not moved from the
amateur to the professional level. As an amateur racer, he is
not eligible to receive cash prizes for racing within the United
States. During 1993, Benjamin won noncash vouchers worth $2,525
that were redeemable for racing merchandise, parts, and
equipment. He turned over $2,250 of the vouchers to petitioner,
who used them to pay for racing expenses.
Benjamin reported gross income in the amount of $2,525 for
the vouchers on his 1993 Federal income tax return. He claimed a
deduction in the amount of $2,250 for management fees. The
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