-11- races as a means of gaining exposure for his sponsor, and otherwise to enter unsanctioned races where he had the best chance of success and the opportunity to win larger prizes. Petitioner was successful in making a profit as predicted in the business plan during 1998. Petitioner was not able to earn a profit as predicted in the business plan, however, during the years at issue, largely because he had lost his sponsorship and was unsuccessful in persuading other local businesses to sponsor him. When petitioner realized that he was not able to earn a profit on the drag racing activity as predicted in his business plan, he decided to liquidate his business and sell his race car. See Engdahl v. Commissioner, supra at 667; Canale v. Commissioner, T.C. Memo. 1989-619 (taxpayer’s decision to leave racing because of its unprofitability supported claim of entering racing with a profit objective). During the years at issue, petitioner decreased the number of races he entered and testified he entered them mainly to market his car. The separate checking account, specific business plan, budget and expense forecasts, and decision to modify the activity when it became unprofitable support petitioner’s contention that he carried on the drag racing activity in a businesslike manner during the years at issue. 2. The Expertise of the Taxpayers or Their Advisers We next consider petitioner’s expertise (or the expertise of his advisers) in the drag racing activity. Preparing for thePage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011