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As a result of a number of factors (namely, the $20 million
that became available to petitioners on the sale of ALS, the
consulting agreement that required little of petitioner's
considerable skill, experience, and time, the broad restrictions
on petitioner's activities to which petitioner became subject
under the covenant not to compete, and petitioner's relatively
youthful age and vigor), after the sale of ALS in 1984,
petitioner began an extensive and businesslike investigation of
business and investment opportunities in which the approximately
$20 million that petitioners had available might appropriately be
invested and to which petitioner might apply his considerable
business talent. Petitioner personally consulted with various
experts and obtained advice regarding market trends and types of
industries that might have unique and positive growth and
appreciation potential.
Over the course of the next few years and as a result of
various activities, investments, and companies in which
petitioners invested and were involved, petitioners earned and
realized very significant income. Assets in which petitioners
invested appreciated significantly, some of which appreciation
petitioners have realized and some of which, as of the time of
trial, petitioners have not yet realized because the assets are
still held by petitioners. Over the years, petitioner has
demonstrated a skill and talent for making a profit.
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