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he worked for the next 33 years. Petitioner also became a
licensed airplane mechanic.
Beginning in 1967, petitioner also became engaged in an
activity that, over the course of the next 34 years, involved the
building, improving, and flying of four small airplanes that
petitioner owned (airplane activity), three of which petitioner
built from kits. When not flying for American, petitioner
personally would spend many hours each week working on his
airplanes, seeking to improve their mechanical operation and
flight speed.
Over the years, including 1994, 1995, and 1996, petitioner
entered his airplanes in a number of air shows and air races.
Flight logs relating to petitioner’s airplanes for 1994, 1995,
and 1996 reflect that petitioner won either first or second place
in five air races. In 1977, petitioner won a national
championship race for the class relating to one of his airplanes.
Only petitioner flew his airplanes in the above air shows and air
races.
In 1994, petitioner installed in one of his airplanes a
direct ignition system that he had developed. Petitioner hoped
that his direct ignition system could replace standard magnetos
typically used in airplanes. Petitioner thought that such a
direct ignition system might improve the speed of airplanes.
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