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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, supplemental stipulation of facts, and
the exhibits attached thereto are incorporated herein by this
reference.
Petitioners resided in Roanoke, Virginia, at the time they
filed the petition in this case. The term petitioner in the
singular will refer to Jay M. Anderson.
In 1980, petitioner began working on a design for a high
fuel/mileage automobile, which he called the "J Morgan I" car
(the J car). In the preceding 5 years, he had read extensively
on the subject of automobile manufacturing and performance but
otherwise had no experience in the field. From his reading, he
perceived that there existed an interest in high mileage cars;
i.e., cars that would get 100 or more miles per gallon. He did
not, however, consult any automobile manufacturers or conduct any
market surveys or studies regarding the feasibility of or
interest in such a car.
On May 21, 1981, petitioner purchased Williams Auto
Alignment (the auto shop) with $40,000 borrowed from First
National Bank of Roanoke. He operated the auto shop as a sole
proprietorship at first, but incorporated the business in 1984.
The auto shop provided petitioner with a facility and personnel
to assist in building the car. The ongoing business of the auto
shop was to perform wheel alignments, for which it charged
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