Harvey J. Davis and Patricia A. Davis - Page 3

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          partner formed M&D Enterprises, Inc. (M&D), to develop and market           
          the product.  Petitioner was president of M&D from 1965 until it            
          was dissolved in December 1995.                                             
               Before he acquired the patent rights, petitioner                       
          investigated the cement product by himself and with the                     
          assistance of an engineer and chemist.  He also investigated the            
          prior owner's books and how the prior owner conducted business.             
          Based on these investigations, petitioner believed that the                 
          product was valuable and that the prior owners had mismanaged the           
          business.  Petitioner established a plant to manufacture the                
          product and a sales force to market the product.  The operation             
          became profitable after 6 years.                                            
               In 1975, petitioner founded and became president of                    
          International Materials Corp. (IMC).  IMC was formed to license             
          the cement product in countries other than the United States.               
          IMC licensed the cement patent to foreign manufacturers.  In the            
          early 1980's, M&D's patent expired, and the company closed its              
          U.S. plant and ceased international licensing.  After the patent            
          expired, M&D could no longer collect royalties.                             
               Since 1980, petitioner has appeared as an expert witness in            
          construction litigation cases.                                              
               In 1994, petitioner acquired a truck stop and restaurant in            
          Cabool, Missouri, now known as Midwest Truck Stop, for $500,000.            
          Petitioner reviewed Midwest Truck Stop’s financial records before           

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