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that petitioner intended to profit from the development and
subsequent sales of the system and related products. See, e.g.,
Snow v. Commissioner, 416 U.S. 500 (1974); Louw v. Commissioner,
T.C. Memo. 1971-326. Nevertheless, petitioners failed to
establish that, with respect to Micron Systems, petitioner
engaged in any activity with regularity and continuity during
1995 so as to consider the activity a trade or business for
purposes of section 162 or 174 for that year.
The operation of petitioners’ vehicles in which the system
had been installed, in and of itself, does not support the
deductions here in dispute. Otherwise, petitioners provided
little detail of what petitioner was doing on a day-by-day basis
during the year in issue. We cannot determine whether he was
actively involved in any research and development or
manufacturing and marketing during that year. Petitioner
explained that prior to 1995 he decided to manufacture and market
the system himself after unsuccessfully attempting to license it,
but there is no evidence that petitioner manufactured anything
during 1995, and, other than his generalized testimony on the
point, there is no evidence that he was otherwise researching or
developing any products for sale or patents during that year.
Based upon the negligible gross receipts for the year in issue,
it also appears that petitioner made very little attempt to sell
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