Jay M. Anderson and Helen B. Anderson - Page 14

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            360, 371 (1986); Allen v. Commissioner, 72 T.C. at 34; sec.                                 
            1.183-2(b), Income Tax Regs.  No one factor nor a majority of the                           
            factors is determinative, and we do not reach our decision by                               
            merely counting the factors that support each party's position.                             
            Taube v. Commissioner, supra at 480; Dunn v. Commissioner, 70                               
            T.C. at 720.                                                                                
                  Keeping in mind these factors, we review various aspects of                           
            petitioner's activity.  Petitioner had no design plans drawn or                             
            otherwise reproduced, no patent, no mold for the production of                              
            copies of the J car, and no records of the production expenses or                           
            of his marketing activities or expenses.  Other than his own                                
            extensive reading on the production of automobiles, petitioner                              
            had no background in the design and construction of an                                      
            experimental automobile.  Petitioner consulted no experts on                                
            design, manufacturing, or marketing.  We cannot assume that the                             
            auto shop mechanics, experienced in automobile alignments, had                              
            expertise in the design and development of a car such as the one                            
            at issue.  The unique feature of the J car, its purported fuel                              
            efficiency of 116.7 miles per gallon, has never been certified or                           
            otherwise verified; the J car has been driven only 5 miles, from                            
            the auto shop to petitioner's home.                                                         
                  Petitioner's marketing activities were minimal at best.  He                           
            ran radio advertisements only where they could be obtained on a                             
            per-inquiry basis, a strangely miserly decision when he termed                              
            the expense of $3,500 for a body mold "not a big expense".  The                             

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