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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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