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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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