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Petitioner has also failed to establish that any of
Fairbanks' assets will appreciate in value. Petitioner claims
that Fairbanks' assets are its intellectual property and not its
computer equipment. At trial, petitioner claimed to have
invented four devices while conducting his consulting activity.
Petitioner consented to discuss only one invention at trial, a
remote-controlled pool heating unit. Petitioner explained that
he would not discuss his other three inventions because he had
not yet applied for patent protection.2
Petitioner estimated that his pool heating unit would earn
him $1 milliion in profit once it was produced and marketed.
Petitioner alleges that this invention alone sustains his
contention that Fairbanks' intellectual property will appreciate
in value.
Petitioner, however, has failed to establish any connection
between his consulting activity and his inventions. Indeed,
petitioner listed "consulting" as Fairbanks' principal business
on his Schedule C for the 1992-97 tax years.
Even if we accept petitioner's claim that Fairbanks' assets
are its intellectual property and we further accept that
petitioner's inventions are somehow connected to his consulting
activity, petitioner has still failed to establish that
2 Petitioner applied for patent protection for the pool
heating unit in February 1999, over 3 years after the year in
issue.
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