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compete for monetary prizes. Some races, known as pylon races,
are held on circular courses that provide starts and finishes at
a single location. For instance, at the National Championship
Air Races held in Reno, Nevada, each September, the "closed-
circuit" course is approximately 9 miles long, and some classes
of participants approach flight speeds of 500 miles per hour. At
this rate of speed, one lap can be completed in little more than
one minute. All of the racing action takes place in clear view
of the spectators. In cross-country races, the participants race
from one geographic location to another.
In 1991, petitioner purchased his first aircraft and began
racing in September 1992. During the years at issue, as well as
years subsequent thereto, petitioner was heavily involved in air
racing. In 1994 and 1995, petitioner designed his own racing
aircraft, the Mach Buster, which he began building in 1995. Some
expenses related to the building of the Mach Buster are at issue
in this case.
In the late 1980s, petitioner became involved in buying,
restoring, and selling classic automobiles. During 1989,
petitioner purchased a 1970 Plymouth Barracuda automobile
(Barracuda), on which he spent several years restoring.
Petitioner had some degree of difficulty selling the Barracuda
but eventually sold it in 1996 at a significant loss. The
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