Sernett v. Comr., T.C. Memo. 2012-334

(hobby loss case; petitioner was experienced auto racer who was employed as telecommunications specialist; petitioner started motorsports company and lost enormous sums over 11-year period, finally showing profit in final year; petitioner kept meticulous records to satisfy recordkeeping requirements rather than assist in making profit; no testimony that CPA consulted to render financial advice; four of nine factors favored IRS, two favored taxpayer and three were neutral; court emphasized significant losses over long period of time and petitioner's failure to reduce expenses or increase income; losses from autoracing activity disallowed).