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agree with petitioner's contention that Benjamin's motocross
racing activity is different from his other children's
extracurricular activities. However, we believe the difference
between Benjamin's and his siblings' extracurricular activities
is not in the nature of the activities (i.e., business versus
personal), but in the amount of time and money spent by
petitioner on those activities. We conclude that petitioner had
personal rather than business motives for incurring the loss in
question on behalf of Benjamin.
Furthermore, the record amply demonstrates that Benjamin has
enjoyed a great deal of success at the amateur level of his
motocross competition and may very well compete at the
professional level at some time in the future. However, we find
that petitioner did not engage in his management activity with
the requisite profit objective necessary to support deductions
under section 162(a) for the taxable year in issue. There was no
possibility that petitioner could have realized a profit from his
management activity during 1993 because Benjamin was an amateur
motocross racer during that year and was not eligible to win any
cash prizes. In fact, Benjamin was not eligible to compete as a
professional for cash prizes until he turned 16 years old on
April 14, 1996. At the age of 17, he had still not become a
professional motocross racer.
If and when Benjamin begins to compete professionally for
cash prizes, petitioner's management activity may be considered
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