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reports, TMI was also sponsored by Glidden, the consumer division
of ICI Paints, North America (ICI), during the 1997 IRL season
and Johns Manville during the 1997 and 1998 seasons.18
For both 1997 and 1998, Glidden was one of TMI’s main
sponsors. Not only was the Glidden name included in the name of
Tony Stewart’s car, the Glidden logo also was prominently
featured on the race car, on Mr. Stewart’s uniform, and in Indy
promotional materials. On occasion, before the races, Glidden
executives, ICI executives, or “other customers from other
divisions” had lunch or dinner with Mr. Menard. Glidden paid
cash sponsorship fees of $1.8 million for 1997 and $2 million for
1998 and offered other financial support estimated to be worth
$550,000, including “clothing for the pit crew, shared food
expense at Indy, as well as over and above promotional support
for the Indy store promotion.”
17(...continued)
income report for the 1998 IRL season also lists Menards as a
sponsor to the extent of $45,000.
18Glidden was a TMI sponsor during both the 1997 and 1998
IRL seasons but did not pay for the 1997 sponsorship until 1998.
As a cash basis taxpayer, TMI did not report Glidden’s 1997
sponsorship fee until it was received in 1998. Although Johns
Manville was not listed on the sponsorship income report for
either year, its logo appeared on TMI’s 1997 and 1998 race cars,
and its national accounts manager, John O’Reilly, testified that
Johns Manville sponsored TMI during both seasons. Accordingly,
assuming that Johns Manville was a sponsor during the 1997 and
1998 IRL seasons, excluding Menards, TMI actually had 10 sponsors
during the 1997 IRL season and 9 during the 1998 IRL season.
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