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the Mustang was delivered to petitioner. The Mustang was street
legal and used by petitioners for personal purposes, but it was
modified by Steeda pursuant to petitioner’s specifications so
that it could be used to compete in open-road racing.
Petitioner decided that the value of the Mustang, or
similarly modified Mustangs, depended upon the car’s ability to
perform. Petitioner’s goal was to set the land speed record for
a street-legal car on a public highway. To this end, he entered
the Mustang in various open-road racing events during the years
in issue. At first the events were few and far in between--
twice a year on desert highways in Nevada. Later, the events
were held three or four times a year on rural highways in Texas
as well as in Nevada. Petitioner lived in Alabama at the time.
He owned a trailer and tow vehicle (Chevrolet Suburban) capable
of transporting the Mustang, and he either drove or towed his
Mustang to the racing events. Occasionally, petitioner leased
the Suburban and trailer to others, mostly friends or
acquaintances who used the equipment to transport cars to various
racing or track testing events. From time to time the location
of a racing event coincided with a business trip that petitioner
was required to make as an employee of Nichols Research. When
this occurred petitioner was reimbursed for his traveling
expenses by his employer.
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