Anthony J. McCarthy - Page 3

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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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