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Shuttle activity was conducted as a sole proprietorship, and all
related expenses were deducted on petitioner’s Schedule C.
Petitioner and the other members of the group did not form a
partnership, nor was there any sort of formal agreement among
them. There were no arrangements with manufacturers or any
government organizations. Petitioner’s role in the Sky Shuttle
project was to market the idea of a suspended light rail transit
system. If the Sky Shuttle concept was sold, then the group
would enter into an agreement among themselves to determine their
respective shares and what each person would do. Even though
petitioner stressed that he was the sole proprietor of Sky
Shuttle, he often referred to “our technology”, “our material”,
or what “we” did with regard to Sky Shuttle activities.
According to petitioner, transportation projects are very
politically driven. In order to build a transit system, or be
accepted to build one, many preliminary steps must be taken. The
Federal Government must recognize the type of transportation
system (i.e., monorail, trolley, suspended light rail, etc.), and
funding must be available and allocated by the Federal, State,
county, or city government. This requires political contacts and
political clout with a Member of Congress who will propose the
system. Petitioner testified that there was no funding available
during the years at issue.
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Last modified: May 25, 2011