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transportation expenses, were paid or reimbursed by his employer.
During the summer of 1991, several close friends of
petitioners’ son were killed in an automobile accident.
Petitioners’ son was supposed to have been with his friends at
the time, but wasn’t. In December of that year, petitioners’
residence and much of its contents were destroyed by fire.
These two events had a significant effect on petitioners’ lives
and lifestyle. Petitioner described the above tragedies as “an
unhappy string of events” that led him and his wife “to the
conclusion that * * * [they] needed to get more out of life
before it was too late.” Petitioners’ catharsis began with an
“automotive buying spree” that included several “performance”
cars, including a 1965 Mustang and two Firebirds, one for
petitioner and one for his son.1
Petitioner’s interest in performance cars, especially Ford
Mustangs, led him to open-road racing,2 a form of automobile
racing that he first learned about in a magazine article.
In 1992, petitioner established Turtle Performance, an
unincorporated association, in order to pursue his interests
1 See Lawrence, “Mustang Lifestyles: Terminal Velocity”,
Mustang Monthly, 94 (Oct. 1994).
2 This is a form of car racing that involves driving over a
90 mile stretch of a public highway that has been closed to
traffic. In the unlimited class, the car that completes the
course in the least amount of time is the winner.
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