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building, collected rents, and found tenants. Petitioner sold
the building during 1991 to pay expenses connected with his
divorce. During 1986, after being approached by an accountant,
petitioner, together with two other physicians, invested in a
company known as Cinevision. Petitioner expected to reap a
profit if Cinevision’s business was successful. Cinevision
experienced difficulties after purchasing additional equipment to
expand its business. Petitioner was involved in meetings with
Cinevision's management in an attempt to resolve the
difficulties.
A tenant in petitioner's apartment building introduced
petitioner to Leland Prentice, who held a patent for a simple and
inexpensive process of color printing (process). Leland Prentice
had licensed the patent to Prentice Color, which in turn made an
agreement with A.B. Dick, a large printing equipment and process
distributor, to market the process to print shops. Prentice
Color had gone bankrupt, allegedly due to A.B. Dick’s failure to
market the process, and a lawsuit was being pursued against A.B.
Dick to dissolve the agreement to market the process and to
recover damages for A.B. Dick’s alleged failure to market the
process. The litigation was settled in 1991.
Leland Prentice had the right to use the process in two
locations, but could not market it, and had come to Florida to
set up a print shop using the process. Leland Prentice also
hoped to market the process once the lawsuit against A.B. Dick
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