John E. and Vicki D. Morrissey - Page 13

                                        -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.                                                                    





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