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deciding the taxpayer's motive for making a guaranty, we examine
the objective facts surrounding the loans rather than the
taxpayer's subjective intent. Kelson v. United States, supra.
Petitioner testified that he made it a practice to participate in
various businesses for the purpose of generating fees for his law
practice. Additionally, petitioner testified that he anticipated
negotiating contracts for D.B. Metalworks and that D.B.
Metalworks did some work for Georgia Power, Oconee Electric
Membership Corporation, and Okmulgee Electric Membership
Corporation. He also testified that he sent Mr. Brown, president
of D.B. Metalworks, only one bill for legal services, which was
for incorporating D.B. Metalworks.
We conclude that petitioner's statements, standing alone,
"do not bear the light of analysis." United States v. Generes,
supra at 106. Although petitioner testified that he anticipated
generating fees for his law firm by negotiating contracts for
D.B. Metalworks, petitioner failed to present any details
concerning fees generated from the work performed by that company
for Georgia Power, Oconee Electric Membership Corporation, and
Okmulgee Electric Membership Corporation. Indeed, petitioner
testified that he sent Mr. Brown only one bill for legal
services, which was for incorporating D.B. Metalworks.
Additionally, petitioner's testimony concerning the other
companies in which he allegedly participated in order to generate
fees for his law practice is only superficial. The testimony
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