Jay M. Anderson and Helen B. Anderson - Page 5

                                                - 5 -                                                   
                  By 1985, petitioner had completed about 80 to 90 percent of                           
            the J car; only some body work remained to be done.  A diesel                               
            engine had been installed, and the mechanical and running gear                              
            was installed and operative.  The J car weighed 1,275 pounds and                            
            had a fiberglass body, a Kubota diesel engine, 3-in-line                                    
            cylinders, a four-speed overdrive transmission, front disk brakes                           
            and rear drum brakes, and Michelin radial tires.  The rear end                              
            came out of an old MG.  Petitioner estimated that the car would                             
            go 70 miles per hour at top speed, but it would have poor                                   
            acceleration characteristics.  Petitioner tested the J car using                            
            a meter gauge to determine its mileage per gallon, which                                    
            petitioner estimated to be 116.7 miles per gallon of diesel fuel.                           
            By 1985, 99 percent of the cost of building the J car had been                              
                  Petitioner testified that he paid for the expenses related                            
            to the development of the J car by using 20 to 30 credit cards to                           
            reimburse the auto shop and by borrowing money from several                                 
            sources.  None of these expenses has been substantiated.  In                                
            1985, when the City of Roanoke experienced a flood, petitioner                              
            lost his records related to the expenses for building the J car.                            
            Petitioner has not made an attempt to reconstruct those records.                            
            Petitioner did have the stubs to the auto shop's checkbook for                              
            some portions of the period of May 29, 1981 through October 25,                             

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