- 7 -7
the latter indicates the likelihood of a profit motive. See
Golanty v. Commissioner, 72 T.C. 411, 432 (1979); Burger v.
Commissioner, 809 F.2d 355, 359 (7th Cir. 1987), affg. T.C. Memo.
1985-523; sec. 1.183-2(b)(2), Income Tax Regs.
Petitioner was clearly an expert in racing in the amateur
context, but we find that the record does not establish that he
was an expert in conducting the activity for profit, or that he
actively sought such expertise elsewhere. Despite the fact that
petitioner personally engaged in motocross racing as an amateur
for 2 years, there is no evidence that he was so engaged on a
businesslike basis or that he sought to earn a profit from that
activity. There is also no evidence in the record that
petitioner managed any motocross racer other than his son.
Although petitioner investigated sponsorship opportunities and
other methods by which his son could potentially earn future
income, there is nothing in the record which establishes that
petitioner studied business and economic practices or consulted
with an accountant to advise him financially about the racing
activity prior to engaging in the activity. Furthermore, there
is no evidence indicating petitioner analyzed the overall cost or
necessary capital investment relative to potential revenue. See,
e.g., Nichols v. Commissioner, T.C. Memo. 1990-546.
This factor favors respondent.
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