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in issue other than the collection sold in 1989, which Mr.
Garrett admitted was before he decided to enter the muscle car
business. Rather, the record indicates that Mr. Garrett
considered the operation of the muscle car museum essential to
his muscle car business. Mr. Garrett testified that it was his
intention to make a profit from his muscle car business in only
two ways: (1) From museum ticket and souvenir sales generated by
the exhibition of the museum's muscle car collection; and (2)
from the sale of some muscle cars displayed in the museum.
Consistent with this statement of intention, the majority of the
evidence presented by petitioners on this issue involved
testimony related to Mr. Garrett's plans for a muscle car museum.
Furthermore, Mr. Garrett testified that no part of his muscle car
business would be viable if the planned museum is unsuccessful.
Therefore, the facts of this case do not reasonably support a
characterization of petitioners' undertakings as separate
activities. Rather, we find that petitioners' business purpose
would be served by carrying out the various activities as a
single enterprise, the muscle car museum.
Petitioners' prospective muscle car business--the muscle car
museum--could not function as a going concern until such time as
it was open to the public. Walsh v. Commissioner, T.C. Memo.
1988-242, affd. without published opinion 884 F.2d 1393 (6th Cir.
1989)(holding that a restaurant could not function as a going
concern until it was open to the public). Mr. Garrett testified
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