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Institute of Technology, and was, at one time, employed as an
engineer by the National Aeronautics and Space Administration.
For the period 1981 through 1994, petitioner has reported
minimal income, and expenses approximating $225,000, in
connection with his Windmill Distillery activity. He did not
maintain a separate bank account for the activity.
Petitioner sought to determine the economic viability of his
Windmill Distillery approach to producing ethanol by preparing a
series of calculations based on data drawn from Government
publications and other publicly available literature and by
informally surveying local farmers about costs of "distressed
corn" that he might use for feedstock. He also attempted to grow
Jerusalem Artichokes in order to test their viability as a
possible alternate feedstock. He concluded that with the proper
facilities, he could produce alcohol at a cost of $1.04 per
gallon. Petitioner never conducted any formal research as to the
marketability of the product he hoped to produce or as to the
cost and availability of necessary raw materials.
During the years petitioner worked on this project, his
duties as an airline pilot generally required him to work 1-to
2-weeks at a time and allowed him to be off work during
alternating 1- to 2-week periods. Petitioner's salary as a pilot
for the years 1988 through 1990, was $133,117, $132,978, and
$146,537, respectively. Petitioner devoted significant amounts
of time to his Windmill Distillery activity during the years in
issue.
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