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received $50,000 and forgiveness of his $116,831 indebtedness to
CRC.4
For 1992, CRC issued Tony a Form 1099-MISC, Miscellaneous
Income (the Form 1099), reporting a $166,831 payment.
Petitioners claim not to have received a copy of the Form 1099.
Tony’s Stock Car Activity
In the late 1960's, Tony became involved in automobile
racing, first by working on pit crews and later by participating
in stock car racing as a hobby. In the early 1980’s, he and
Robert purchased an automobile racetrack located in the city of
Oregon, Wisconsin, and ran it for a couple of years.
In 1991, Tony remortgaged his house for $50,000 to finance
construction of a stock car for asphalt automobile racing. His
goal was to have a stock car ready for racing in the American
Speed Association’s (ASA’s) 1992 racing season. During 1992,
Tony had a stock car (the stock car) built to ASA standards,
hiring an Illinois contractor to build a body for the Oldsmobile
chassis and a Wisconsin contractor to install the parts.
4 On their 1992 Federal income tax return, petitioners
reported a sale price of $800,000 for the joint ventures.
Petitioners reported the transaction as an installment sale,
showing that in 1992 they received $699,925 of the total $800,000
sale price and that they had realized $73,894 of capital gains in
1992 under the installment method. Respondent has raised no
issue regarding petitioners’ income tax reporting of Tony’s sale
of his interests in the joint ventures.
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