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does not establish an extensive or continuous activity of
promoting corporations for sale as to constitute a separate trade
or business.
Petitioner has not established that he provided promotional
services to the companies he owned. Except for the blueprinting
company in the early 1960's, there is no evidence that petitioner
provided anything but financing to the companies. Petitioner did
not actively seek out companies to promote and did not advertise
the companies he had. On tax returns for 1985 through 1988,
petitioner reported income and loss from business enterprises
separate from BEI as passive income and loss. Petitioner's
primary activity with regard to BEI was to attend board of
directors' meetings where he discussed financing for the BEI
subsidiaries and acquiring additional businesses. These
activities do not differ from those an investor would take to
protect and expand his investments. Petitioner has not
identified promotional services that he provided to the BEI
subsidiaries for which he would have been compensated upon the
resale of one of the BEI subsidiaries.
The record in this case does not reflect the amount of time
that petitioner spent involved in managing or operating the BEI
subsidiaries. We note that petitioner indicated that he devoted
a significant amount of time to ENSCO during 1986 to 1988 and
received a salary exceeding $300,000. Petitioner attributed his
inability to successfully rehabilitate the BEI subsidiaries to
the time demands of ENSCO. There was no showing by petitioner
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