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recreational elements associated with the activity. See sec.
1.183-2(b)(3), Income Tax Regs. Petitioner devoted 40 hours a
week to the activity including working on his race car and two to
three nights attending races. At the same time, petitioner found
automobile drag racing extremely enjoyable. In spite of a
serious heart condition, petitioner described competitively
driving the race car as a stressful, exhilarating experience that
he enjoyed repeating. Therefore, on balance, this factor neither
supports nor detracts from petitioner's position.
4. Expectation That Assets May Appreciate
An expectation that assets used in the activity may
appreciate in value may be an indication of a profit objective.
See sec. 1.183-2(b)(4), Income Tax Regs. During his involvement
in the automobile drag racing activity, petitioner spent over
$100,000 on the sole asset of the activity, the race car.
Petitioner thought that he might be able to sell the race car for
$40,000 to $50,000. Therefore, petitioner had no expectation
that the race car would appreciate in value. In fact, the
highest offer petitioner has received for the race car is
$20,000, and he realizes that used race cars "don't bring in
money." Accordingly, this factor weighs against petitioner.
5. Taxpayer's Success in Other Activities
The success of the taxpayer in carrying on other activities
can be some indication of whether the taxpayer had a profit
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