- 10 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011