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Respondent determined deficiencies of $6,225 for 1999,
$6,687 for 2000, and $5,866 for 2001 in petitioners’ Federal
income taxes. The issue to be decided is whether petitioner John
E. Morrissey (petitioner) operated his automobile drag racing
activity for profit during 1999, 2000, and 2001 (the years at
issue). We hold that he did.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the accompanying exhibits are
incorporated by this reference. Petitioners resided in Wetmore,
Kansas, at the time they filed the petition in this case.
Petitioner has been interested in cars throughout his life
and has been involved from time to time in some type of
automobile racing since 1969.
Petitioner graduated from Emporia State University in 1970
with a degree in business administration. His studies included
courses in marketing and mathematics. During the years at issue,
petitioner was the senior vice president and chief financial
officer of Kansas State Bank of Holton, Kansas (the bank), a
full-time position.2 He earned a salary of approximately $58,000
during each of the years at issue. Petitioner also served on the
board of directors of the bank. Petitioner oversaw the bank’s
financial planning, budgeting, and statistical analysis
2Petitioner Vicki D. Morrissey was also employed full time
at the Wetmore, Kansas, branch of the bank during the years at
issue.
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