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Petitioner is a graduate of the U.S. Air Force Academy and
retired after a career in the Air Force. He possesses dual
degrees from the Air Force Academy in aeronautical engineering
and political science. He also has advanced degrees from other
institutions of higher learning. While petitioner was on active
duty in the Air Force, he developed an interest in the Porsche
automobile, which is manufactured in Germany. Although Porsche
produced several types of engines, petitioner was particularly
interested in the Porsche 928 S4 engine. From the evidence
adduced at trial, it appears that this engine was designed to run
comfortably at speeds of 130 to 150 miles per hour; however, the
engine was not designed for racing. Petitioner became interested
in developing modifications to the engine that would increase the
engine's horsepower so that the car would be adaptable for racing
and still could be used as a regular street vehicle. Petitioner
felt that there was a niche in the market for this type of
vehicle, although the manufacturer, Porsche, was not interested
in producing such an engine for the reason that Porsche offered
other types of engines for racing purposes. The Porsche 928 S4
2(...continued)
not claimed on their return. In the written stipulation filed at
trial, with respect to the $18,305 disallowed expenses,
respondent conceded that petitioners were entitled to a deduction
for $11,305 of these expenses, leaving at issue $7,000,
representing the cost of the automobile engine referred to in the
statement of issues.
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Last modified: May 25, 2011