- 14 - 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.”Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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