Jay M. Anderson and Helen B. Anderson - Page 15

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            two or three radio stations running these advertisements were in                            
            California; petitioner and the J car were in Virginia.  The                                 
            magazines that supposedly printed petitioner's flyers were                                  
            distributed in Europe.  Petitioner provided no proof of these                               
            purported sales efforts or of his marketing to manufacturers,                               
            although the loss of his records occurred in 1985, not in 1989                              
            and 1990 when he allegedly was spending 25 hours a week on his J                            
            car-related activities.  We doubt that the minimal marketing                                
            activities that petitioner described consumed the 25 hours per                              
            week he claims.                                                                             
                  The two inquiries that came to petitioner--the Texas man                              
            with a corporate shell who was searching for an operating                                   
            business to put into his shell, and the individual with a patent                            
            on a new motor who was looking for a car in which to put his new                            
            motor and who had been dealing with a Brazilian company--seem to                            
            have been wholly fortuitous and without any effort on                                       
            petitioner's part.  Moreover, these were casual inquiries at best                           
            and were never reduced to writing.                                                          
                  Petitioner made no profit, indeed no income, from this                                
            activity.  He was involved in no other similar activities.  His                             
            primary occupation was a mortgage loan business and real estate                             
            investments.  Petitioners' major sources of income during 1989                              
            and 1990 were from the sale of real property and interest.  While                           
            it is unlikely petitioner entered into the J car activity with a                            

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