Tony L. Zidar and Kathleen I. Zidar - Page 14




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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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