Jay M. Anderson and Helen B. Anderson - Page 10

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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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