- 20 -- 20 -
Commissioner, 66 T.C. at 24-25 (corporation recognized because it
owned insurance, borrowed money, and had a checking account).
Rosewood Kennels, Inc., did considerably more than the
corporations in Paymer and Strong. Rosewood Kennels, Inc., owned
26 acres of land which it used as collateral. It borrowed
$500,000. It applied for and obtained insurance policies. It
sent its customers invoices which showed that it sold equipment
and provided services to them in 1990.
Petitioners contend that Rosewood Kennels, Inc., did not
engage in business in 1990. We disagree. A significant amount
of documentary evidence contradicts their testimony.
2. Cases Cited by Petitioners
Petitioners contend that we should disregard their
corporation just as we did the corporations in Blue Flame Gas Co.
v. Commissioner, 54 T.C. 584 (1970); Barker v. Commissioner, T.C.
Memo. 1993-280; and Bystry v. United States, 596 F. Supp. 574
(W.D. Wis. 1984). We disagree.
The taxpayers in Blue Flame Gas Co. v. Commissioner, supra,
had a partnership when they filed articles of incorporation.
They contributed no property to the corporation. The corporation
did no business and was abandoned. We held that the losses at
issue were attributable to the partnership. Id. at 599. In
Barker v. Commissioner, supra, we held that the business should
not be taxed as a corporation because it lacked assets and had no
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