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In the early 1970s petitioner was engaged in manufacturing
and selling filament tape and pressure-sensitive labels. In the
late 1970s, petitioner obtained a contract with the General
Services Administration (GSA) under which he sold approximately
$600,000 worth of filament tape to the Federal Government. The
contract was canceled by GSA because the tape failed to meet
contract specifications, and the defective tape was returned to
petitioner. Thereafter, petitioner no longer manufactured
filament tape and did not purchase any additional products for
resale.
Petitioner stored the defective tape in a shed in his wife's
backyard. Petitioner was married in 1949, but he and his wife
have lived apart for at least 20 years. Since 1979, petitioner
has attempted to sell the tape, which petitioner describes as
"about $500,000 worth of material", but without success.
Petitioner owed the Small Business Administration (SBA) $500,000
on a loan made in connection with his efforts in the filament
tape business, and the SBA confiscated petitioner's equipment and
other business assets in the early 1980s to cover some of the
loans it had made to petitioner.
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