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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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