Stanley M. Kurzet and Anne L. Kurzet - Page 5

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                  As a result of a number of factors (namely, the $20 million                         
            that became available to petitioners on the sale of ALS, the                              
            consulting agreement that required little of petitioner's                                 
            considerable skill, experience, and time, the broad restrictions                          
            on petitioner's activities to which petitioner became subject                             
            under the covenant not to compete, and petitioner's relatively                            
            youthful age and vigor), after the sale of ALS in 1984,                                   
            petitioner began an extensive and businesslike investigation of                           
            business and investment opportunities in which the approximately                          
            $20 million that petitioners had available might appropriately be                         
            invested and to which petitioner might apply his considerable                             
            business talent.  Petitioner personally consulted with various                            
            experts and obtained advice regarding market trends and types of                          
            industries that might have unique and positive growth and                                 
            appreciation potential.                                                                   
                  Over the course of the next few years and as a result of                            
            various activities, investments, and companies in which                                   
            petitioners invested and were involved, petitioners earned and                            
            realized very significant income.  Assets in which petitioners                            
            invested appreciated significantly, some of which appreciation                            
            petitioners have realized and some of which, as of the time of                            
            trial, petitioners have not yet realized because the assets are                           
            still held by petitioners.  Over the years, petitioner has                                
            demonstrated a skill and talent for making a profit.                                      






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