- 16 -
noticed, the logo was seen at the start of the races as well as
in the paddock areas, where spectators gathered to get a closer
look at the cars and provided Mr. Ciaravella with the opportunity
to meet and greet potential customers. The fact that Valvoline
and Champion compensated Mr. Ciaravella for displaying their
logos indicates that the advertising exposure provided by these
races did provide its sponsors with some economic benefit. Most
importantly, the contacts made at the races during the years in
issue were helpful in selling and leasing aircraft, the record
indicating at least one highly profitable sale in a later year
that resulted from Mr. Ciaravella's racing activities.
Accordingly, we conclude that the race car expenses are
necessary, in the accepted sense of being helpful.
The connection between racing cars and advertising a
business that leases and sells jet aircraft is a stronger
connection than the connections put forth by petitioners in Gill
v. Commissioner, supra; Boomershine v. Commissioner, T.C. Memo.
1987-384; and Brallier v. Commissioner, supra. Each of the above
cases also deals with a corporation that paid the race car
expenses of its sole shareholder and claimed deductions for the
payments as advertising expenses. In those cases, this Court
also found that the expenses were ordinary and necessary but only
allowed a portion of the race car expenses to be deducted. The
petitioner in Gill raced a stock car to advertise his wholly
owned corporation's quilting and stencil business. The
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