- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011