- 23 -- 23 -
They signed many documents that clearly stated that Rosewood
Kennels was incorporated and that petitioners were its officers.
Some of the documents included the corporate seal. We believe
that petitioners knew what they were signing. For example,
petitioners knew that they conveyed 26 acres of land to Rosewood
Kennels, Inc., on June 2, 1990. Rosewood Kennels, Inc., used the
26 acres of land as collateral when it borrowed $500,000.
Petitioners' claim of ignorance is unconvincing.
Petitioners contend that it is insignificant that petitioner
signed her name as "president". Petitioner testified that she
did not think that a "president" was a corporate officer.
Petitioners' denial is not credible.
Petitioners contend that the fact that they used JAM
Bonding's Federal identification number on documents for Rosewood
Kennels, Inc., shows that Rosewood Kennels, Inc., was not
incorporated and that it did not do business as a corporation.
We disagree. Petitioners offer no authority for their position.
Petitioners point out that Rosewood Kennels, Inc., filed a
Federal tax return with all zeros for 1990. That fact does not
necessarily lead us to disregard it as a corporate entity. See
Strong v. Commissioner, supra at 24.
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