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course of Brassworks’s business, petitioner fabricated brass
radiator reproductions for Model T Fords and shipped them
worldwide to customers who restored those automobiles, and
petitioner also restored Model T Fords for resale at auctions.
From 1976 through 1993, petitioner worked full time for
Brassworks, and the Gouveias were the sole proprietors of the
business from 1984 until 1993.
In March 1993, the Gouveias sold Brassworks for $661,725 to
Inga, Inc., a corporation established by William and Debra
Ingalls to purchase the business. Inga, Inc. paid the Gouveias
part of the purchase price as a downpayment and executed two
promissory notes and an installment note for the remaining
amount. The principal amounts of the promissory notes were
$35,000 and $16,240, which were payable, with interest, on their
respective maturity dates of March 8, 1995, and March 8, 1999.
The principal amount of the installment note was $363,877.30,
which was payable to the Gouveias, with interest, in monthly
installments of $4,100 beginning on June 8, 1993. As part of the
sale of Brassworks, petitioner agreed that he would no longer
manufacture any brass radiators or water pumps.
B. The Gouveias’ Real Estate Investments
In October 1987, the Gouveias purchased a half acre of
unimproved land located at 285 and 289 Prado Road, San Luis
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Last modified: May 25, 2011