Alexander M. Moye and Judy H. Moye - Page 22

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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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