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Petitioner decided at some point that he would try to sell
or license the J car itself to an automobile manufacturer. He
wanted a flat sum, plus a certain amount per each unit the
manufacturer made. He received an inquiry from an individual in
Texas who had a corporate shell and was looking for an operating
business to place in his shell. That person thus was not
interested in petitioner's proposed venture. Petitioner related
that he declined the offer of a company in Brazil that wanted to
exchange $100,000 of its stock for the car, plus $50 per each car
made.6 Petitioner did not want stock that was not traded
publicly, and the company apparently would not guarantee that a
specific number of units would be manufactured. Petitioner
wanted a guarantee of a minimum of 1,000 units. This offer,
whatever its terms, was never put in writing.
Petitioner testified that during the years at issue he spent
about 25 hours per week on the J car activity; however, the few
activities detailed above were rather brief and sporadic and
could not have consumed that much time. During this time,
6 Petitioner's friend put him in contact with an individual
who had been dealing with the Brazilian company. That individual
had a patent on a new motor and was searching for a car in which
to use his motor. It is not clear whether petitioner dealt just
with that patent holder or dealt directly with a representative
from the Brazilian company.
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