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Petitioner and Mr. Takos agreed that the day-to-day
management of the corporation would be handled by Mr. Takos,
since he was locally based as a real estate agent in Dubuque,
Iowa. These duties required only a nominal portion of Mr. Takos'
time. Petitioner was responsible for carrying out the basic
functions of the corporation. His services to the corporation
included: Traveling twice to Europe, in 1977 and 1978, to
conduct a market study regarding the aims of the corporation and
establishing a process for finding appropriate clients or
investors; establishing contacts with reputable real estate
agencies throughout the United States toward seeking and
selecting appropriate properties; visiting selected properties,
making feasibility studies, and preparing a portfolio for sales
presentations; traveling to Europe for consultations and sales
presentations with selected agents and customers; and resolving a
variety of international problems relating to each client, such
as visas, immigration, commercial treaties, etc. Petitioner
generally worked about 20 hours per week for the corporation
during the academic year and 50-60 hours per week during the
summer months. Petitioner maintained his employment with the
University as a professor.
During petitioner's first trip to Europe in 1977, it became
clear that the Europeans would not deal with the corporation
unless the corporation established creditworthiness. When the
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