Tax Depreciation of Race Car

If race car is used 100% for racing (taxpayer's only business activities are racing related) is it still subject to auto limitations? I believe so but was just wondering if there may be a exception.

I think not, but here's a PLR about when certain acts constitute a disposition under MACRS. https://www.irs.gov/pub/irs-wd/201710006.pdf

Race cars aren't passenger automobiles.

In a sincere desire for guidance (I'm a race car and classic, antique, and muscle car enthusiast), can you link some authorities that expand on Class Life 00.22 as far as the meaning of Automobiles?

Would they have to go into Class 79.0, Recreation? I hope not. As one can glean from the plr I linked above, many of these cars are constantly being repaired, rebuilt, etc.

Coddingon's input w/b welcome.

Race cars aren't passenger automobiles.. Many are not, but some are. Like, say, a '68 Camaro.

The case involves a home and real estate development construction company that was under audit by the Internal Revenue Service for 2013. During the course of the audit the company was found to have buried in its construction expenses over $121,000 of expenses related to the cost and parts for a ’68 Camaro that was used as a race car by the son of the company’s founder.

https://www.rhsmith.umd.edu/research/wh ... nteresting

From the Berry case:

Expenses paid in 2013 with respect to the 68 Camaro would be deductible, if at all, through depreciation or as startup expenses ...

and

If the 68 Camaro were a depreciable asset, the cost of acquiring the race car and getting it ready for racing would constitute an acquisition cost that is not currently deductible. See sec. 1.263(a)-2T(d), (k), Temporary Income Tax Regs., 76 Fed. [*16] Reg. 81102, 81107 (Dec. 27, 2011). A capital asset that is used in an activity for profit may be depreciated beginning for the tax year in which the asset was placed in service. Sec. 1.167(a)-10(b), Income Tax Regs.

. Fven though the wording includes "if at all" and "if the 68 Camaro were a depreciable asset", that douby seems to relate to whether there was a business at all and whether that business had begun in the year the expenses were claimed.

Many start as stock cars but are so modified that they are no longer street legal. But, ... https://www.rookieroad.com/nascar/are-n ... ar-example. See the heading Street Legal NASCAR Car Example.

Would they have to go into Class 79.0, Recreation? I hope not.

IRS says "yes."
https://www.irs.gov/pub/irs-wd/0052019.pdf

Nice find. Pretty tentative, though. In the real world, those cars do not last 10 or even 7 years.