Richard D. Anderson and Mary L. Anderson - Page 2




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          action for tortious interference with business relations are                
          excludable from petitioners’ income under section 104(a)(2).1               
                                  FINDINGS OF FACT2                                   
               Petitioners resided in Chamblee, Georgia, when their                   
          petition was filed.  Richard D. Anderson was a director,                    
          officer, shareholder, and employee of ARRE Industries, Inc.,                
          d/b/a Carrera Shocks (Carrera).  Mary Anderson was an officer               
          and employee of ARRE Industries, Inc.                                       
          Carrera Shocks                                                              
               In 1964, Mr. Anderson started a highly specialized business            
          to research, develop, and manufacture high performance                      
          suspension component parts for race cars.  In particular, he                
          designed shock absorbers.  Mr. Anderson held three patents                  
          related to shock absorbers.  Carrera’s main customers were                  
          distributors of racing equipment who in turn would sell the                 
          shock absorbers to auto racing teams.  Mr. Anderson’s                       
          familiarity with auto racing permitted him access to the pit                
          crews and provided him with the opportunity to perform                      
          consultations regarding the most efficient use of Carrera shock             
          absorbers.  While attending approximately 100 races per year                


               1 All section references are to the Internal Revenue Code in           
          effect for the years in issue, and all Rule references are to the           
          Tax Court Rules of Practice and Procedure, unless otherwise                 
          indicated.                                                                  
               2 The stipulation of facts and the attached exhibits are               
          incorporated herein by this reference.                                      




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