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prominent figures through his racing activities. As a result of
a contact that Mr. Ciaravella made at one of his races, on
August 14, 1996, Dolphin sold a Learjet to a Las Vegas
construction company for $1,925,000. Mr. Ciaravella claims that
his racing activities resulted in other contacts that have led to
the sale and lease of aircraft by Dolphin. Dolphin reimbursed
Mr. Ciaravella for the bulk of the expenses connected with his
racing activities, treating them as advertising expenses.
Mr. Ciaravella's race car also bore the logos of Champion,
Checkers, and Valvoline during the years in issue; in return, he
received free spark plugs from Champion and free oil from
Valvoline. Dolphin has never sponsored or placed its logo on any
other race car.
During fiscal periods ending August 31, 1991, August 31,
1992, and August 31, 1993, Dolphin used the following five
advertising accounts:3
Account No. Trade Magazine/Publication/Other
6051 (a) Trad-A-Plane
(b) Clubhouse
(c) Mcgraw
(d) Trader Publication
(e) Remuo
6052 (a) Trad-A-Plane
(b) Thurot Tech Aviation
(c) Bham News
3 It is not clear why five separate accounts are used, nor
is it clear why the name of some publications appear in more than
one account.
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Last modified: May 25, 2011