John E. and Vicki D. Morrissey - Page 4

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          functions.  Petitioner also served on the loan committee and                
          designed the review mechanism by which the members of the bank’s            
          loan committee assessed loan applicants.                                    
               Petitioner believed that his business degree and technical             
          skills could be an advantage to him in drag racing.  Petitioner             
          began competing about 1974, beginning with a relatively simple              
          car and then moving up.  Petitioner applied his extensive                   
          knowledge of mechanics, mathematics, and physics to make                    
          important technical modifications to his car.  For example,                 
          petitioner installed electronic equipment intended to fine-tune             
          the car’s reaction time.  Petitioner is a skilled mechanic and              
          was able to perform almost all of the work on his car himself.              
               Petitioner also kept detailed computer records of his car’s            
          performance during each race, including weather conditions, heat            
          times, and records of opponents’ performances.  Petitioner                  
          thought these records would help him identify the ideal                     
          attributes of his car to enable him to win races.  Petitioner               
          also often spoke to other competitors and assessed their                    
          strategies.  Petitioner also examined less successful competitors           
          in an attempt to determine why those competitors were not                   
          successful.  Petitioner began winning rounds of competition in              
          1991 and races in 1993.                                                     
               Petitioner carefully organized his racing schedule to                  
          compete in races where he had the greatest chance of success.               
          During the years at issue, petitioner raced mainly at                       
          unsanctioned or “outlaw” racetracks, which had lower entry fees             





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