Jay M. Anderson and Helen B. Anderson - Page 3

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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                               
                  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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