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do not believe that Onni decided the contents of and printed and
used petitioners' business letterhead without their knowledge.
4. Some Documents Were Silent About Rosewood Kennels'
Corporate Status
Petitioners point out that some of the documents in the
record did not state that Rosewood Kennels was incorporated in
1990, and some documents refer only to the Southern Police Dog
Academy. Petitioners also point out that not all of the
documents that called for a corporate seal had one. Petitioners
contend that these facts show that it did not do business as a
corporation. We disagree. Rosewood Kennels, Inc., clearly owned
property, borrowed money, had insurance, and did business.
5. Whether Petitioners Knew That Their Police Dog Training
Business Represented Itself as a Corporation
Petitioners deny that they were responsible for or knew
about the many legal and financial documents that they signed
that referred to Rosewood Kennels as a corporation. They contend
that they did not know that they transferred property to Rosewood
Kennels, Inc., or that it had applied for and received an SBA
loan and various insurance policies because they did not prepare
the documents for those transactions. We disagree.
Petitioners are reasonably sophisticated about business.
They founded JAM Bonding, which had gross receipts of more than
$500,000 in 1988. They delayed incorporating JAM Bonding so they
could deduct its losses on their personal returns.
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