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2. Race Car Expenses--1987 and 1988
As indicated in our findings of fact, we are satisfied from
the record that petitioner incurred deductible expenses in
connection with his car racing business. Accordingly, an
estimate must be made under Cohan v. Commissioner, supra.39
Petitioner testified that each year he raced the car
approximately 10 times at the speedway in Busti, New York.
Petitioner indicated that his race car expenses included:
Gasoline, oil, tires, A-frames, ball-joints, spark plugs, spark
plug wires, distributor caps, pit entrance fees, paint, and
miscellaneous car repairs (including parts). Petitioner
testified with particularity, however, only with respect to the
pit entrance fees and tire expenditures. Petitioner indicated
that each week during the racing season he paid a total of $20 in
pit entrance fees for himself and a helper; and that every other
week he replaced the rear tires at a cost of $50 to $55 per tire.
From the record we find that petitioner incurred deductible
expenses of $750 for each year in issue (i.e., 1987 and 1988).
Cohan v. Commissioner, supra.
3. Truck Expenses--1990
Petitioner claimed truck expenses for the Bullfrog in the
39 As respondent failed to argue the applicability of sec.
274(d)(4) with respect to the race car expenses claimed by
petitioner, we conclude that respondent has conceded that
petitioner's race car is not listed property subject to the
substantiation requirements of sec. 274(d).
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