Alexander M. Moye and Judy H. Moye - Page 21

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                    business activities.  In Bystry v. United States, supra at 576,                                                                                        
                    579, the taxpayers transferred no land or other assets to their                                                                                        
                    business and never did business as a corporation.                                                                                                      
                              Petitioners point out that the taxpayers in Barker and                                                                                       
                    Bystry had no corporate bank accounts and contend that this fact                                                                                       
                    is dispositive.  We disagree.  In contrast to the facts in those                                                                                       
                    cases, Rosewood Kennels, Inc., owned property, borrowed money,                                                                                         
                    obtained insurance, and did business.                                                                                                                  
                              3.        The Invoices                                                                                                                       
                              Petitioners contend that their employee, Onni, had the                                                                                       
                    Rosewood Kennels, Inc., letterhead printed and used it without                                                                                         
                    their knowledge.  Petitioners both testified that Onni concluded,                                                                                      
                    without petitioner's telling him, that Rosewood Kennels was                                                                                            
                    incorporated, and that petitioner was president and Mr. Moye was                                                                                       
                    secretary/treasurer.  We do not find petitioners' testimony in                                                                                         
                    this regard to be credible.  We decide whether a witness is                                                                                            
                    credible on the basis of objective facts, the reasonableness of                                                                                        
                    the testimony, the consistency of statements made by the witness,                                                                                      
                    and the demeanor of the witness.  Quock Ting v. United States,                                                                                         
                    140 U.S. 417, 420-421 (1891); Wood v. Commissioner, 338 F.2d 602,                                                                                      
                    605 (9th Cir. 1964), affg. 41 T.C. 593 (1964); Pinder v. United                                                                                        
                    States, 330 F.2d 119, 124-125 (5th Cir. 1964); Concord Consumers                                                                                       
                    Hous. Coop. v. Commissioner, 89 T.C. 105, 124 n.21 (1987).                                                                                             
                    Petitioners' testimony about the letterhead was implausible.  We                                                                                       





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