- 15 - 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 aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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