-4-
and typically more prize money. Although the National Hot Rod
Association (NHRA) licensed petitioner in the Super Comp
category, petitioner viewed NHRA-sanctioned events merely as
opportunities to gain exposure for his sponsor. The entry fees
at NHRA-sanctioned events were higher, the prizes were not as
large, and there were many more competitors.
Petitioner prepared detailed budget forecasts and expense
estimates for his racing activity for the years at issue, which
he modified throughout each year as circumstances changed.
Petitioner also kept a separate checking account for his racing
activity.
Petitioner entered eight drag races in 1999, eight drag
races in 2000, and six drag races in 2001. Petitioner’s son also
raced petitioner’s car at some races during the years at issue.
Although the bank employed petitioner full time during the years
at issue, petitioner was able to take the time to attend to the
necessary aspects of his racing, such as repairing his car,
contacting sponsors, and participating in races. The amount of
time these activities took varied according to, for example, the
amount of repairs needed after a race. Petitioner’s wife and son
also assisted petitioner with these activities on occasion.
Petitioner believed that he owned a quality car and used
quality parts in its maintenance. Petitioner hoped that his car
would hold its value as much as possible but did not expect that
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