Michael P. and Pamela J. Hopkins - Page 3

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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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