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During the period (1965-1979) he worked for Goodyear, Mr.
Hopkins, who participated in drag racing as a teenager, fre-
quently attended automobile races. In 1980, Mr. Hopkins stopped
frequenting such races. In 1985, he resumed attending automobile
races, frequenting about 8 to 10 races a year. In at least 1999,
the year at issue, Mr. Hopkins attended automobile races in
different places throughout the United States, including Arizona,
California, Indiana, Kentucky, Pennsylvania, and Texas.
From 1982 until around mid-June 1999, Mr. Hopkins, operating
as a sole proprietor under the name MPH Enterprises (Mr.
Hopkins’s sole proprietorship), sold on behalf of certain manu-
facturers, including Westchem, Inc. (Westchem), various plastics
products and equipment used in the medical profession and the
construction industry. In return for such services, Mr. Hopkins
received sales-based commissions from such manufacturers. During
approximately the first 5� months of 1999, Mr. Hopkins’s sole
proprietorship sold on behalf of Westchem certain Westchem
plastics products that resulted in (1) sales commissions to that
sole proprietorship of an unspecified amount that was less than
$128,6102 and (2) approximately $2.5 million of gross sales to
2As discussed below, petitioners reported that during 1999
Mr. Hopkins’s sole proprietorship had $128,610 of gross receipts
(i.e., sales commissions). Westchem was not the only customer of
Mr. Hopkins’s sole proprietorship, and the record does not
disclose the amount of gross receipts (i.e., sales commissions)
that Mr. Hopkins’s sole proprietorship received from its other
(continued...)
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