-12- activity by extensive study of its accepted business, economic and scientific practices and consulting with experts in these matters may indicate that a taxpayer has a profit objective when the taxpayer follows that advice. Sec. 1.183-2(b)(2), Income Tax Regs. There is no question that petitioner has significant expertise in drag racing. Petitioner has been involved in drag racing since 1969 and began winning rounds of competition in 1991. Petitioner is a skilled mechanic and was able to perform most of the required work on his car himself. Petitioner studied the performances of his car and his opponents’ cars (and kept records of these performances) to determine the ideal characteristics for his car. Petitioner also often consulted with competitors to learn about their tactics and strategies. Petitioner also has considerable business knowledge. He was the senior vice president and chief financial officer of the bank during the years at issue. While pursuing his degree in business administration, petitioner took courses in marketing and mathematics. These skills proved valuable to petitioner in creating business plans and budget forecasts and doing the necessary marketing to obtain a sponsor. Petitioner has demonstrated that he has significant knowledge and expertise both in drag racing itself and in the business world. Petitioner has also shown that he consulted others to further his knowledge and improve his prospects of success.Page: 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