-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 thatPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011