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rubbed shoulders with corporate executives at the race track, he
thought he would be able to convince them to provide him
sponsorships. We are unpersuaded, however, that this was
anything more than a false hope. Large sponsorships never
materialized.
We conclude that this factor weighs heavily against
petitioners.7
2. Expertise of Taxpayer or Advisers
In analyzing profit motive, a distinction must be drawn
between expertise in the mechanics of an activity and expertise
in the business, economic, and scientific practices relating to
its conduct. See Burger v. Commissioner, supra at 359; cf. sec.
1.183-2(b)(2), Income Tax Regs. Although Tony had a longstanding
interest in car racing, read car-racing magazines, owned a
racetrack with Robert for a while, and had contacts with some
mechanics and drivers, the record does not establish that Tony
had any expertise in the economics or business of owning and
racing a stock car. There is no evidence that he studied
accepted business practices of stock car racers or consulted with
economic experts in the field.
This factor favors respondent.
7 On reply brief, petitioners concede that “Tony is weak
regarding this factor * * * Petitioners would admit that this
factor weighs against them.”
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