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from corporate promotion activities. United States v. Henderson,
375 F.2d 36, 41 (5th Cir. 1967).
Accordingly, we conclude that petitioner was not in the
trade or business of promoting corporations. Moreover, even if
petitioner were engaged in a promoting business, we would not
conclude that the business encompassed his activities regarding
Color Trick. Petitioner’s activities in connection with Color
Trick were more consistent with those of an investor rather than
those of a business promoter. Petitioner’s loans and advances to
Color Trick were used to finance its operations and to purchase
equipment, which furthered Color Trick’s business. Petitioner’s
rendering of advice and making advances to Color Trick did not in
themselves amount to a promotion of the corporation. United
States v. Clark, 358 F.2d 892, 895 (1st Cir. 1966).
Furthermore, petitioner’s testimony indicates that the only
return he expected for his investments in Color Trick was from
dividends or the long-term enhancement of his share holdings
generated from the profits to be derived from the success of
Color Trick's business. Petitioner may also have hoped to share
in any recovery from a lawsuit against A.B. Dick in connection
with a license it was granted to market the process. Petitioner
further appears to have expected some return from the
exploitation of the patent once A.B. Dick’s licensing agreement
was dissolved in connection with the litigation. Petitioner took
no salary from Color Trick, and there is no evidence that he
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