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petitioner had no control over the income from this activity,
because, in his own words, "at any given time the [race car]
engine could just flip off at the line". In the event such an
engine failure occurred, petitioner did not have the financial
resources to replace his race car's engine quickly and continue
this activity.
We find that petitioner did not operate the activity in a
businesslike manner. This factor weighs against petitioner.
2. Expertise of Taxpayer or Advisers
Preparation for the start of an activity through extensive
study of its accepted business, economic, and scientific
practices, or consultation with those who are experts therein,
indicates that a taxpayer has entered into an activity for
profit. See sec. 1.183-2(b)(2), Income Tax Regs. Petitioner
read car-racing magazines and consulted with mechanics and other
racers. However, there is no evidence that the persons with whom
petitioner consulted had made a profit in car racing or advised
petitioner on how to make one, or that they were other than
racing fans or hobbyists. Accordingly, we find this factor does
not help petitioner.
3. Time and Effort Expended in Activity
The time and effort expended by the taxpayer in carrying on
the activity is an indication of whether a profit objective
existed, particularly if there are no substantial personal or
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