Nathanael Roman - Page 21

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               The testimonial evidence regarding the claimed Schedule C              
          losses for TFC Engineering consists of the testimony of Ms.                 
          Ridgway and Matthew Roman.  Ms. Ridgway testified that around               
          1989 she managed mobile homes and automobile sales for peti-                
          tioner.  We question Ms. Ridgway's testimony.  Indeed, petitioner           
          acknowledges on brief that Ms. Ridgway was mistaken when she                
          testified that she performed those functions for him around 1989.           
          Petitioner claims that Ms. Ridgway did not manage mobile homes              
          for him until 1991.  Petitioner also claims that Ms. Ridgway                
          first managed automobile sales for him during 1990.  Ms. Ridgway            
          also testified that she received around $2,900 during 1990 and              
          some undisclosed amount during 1991 from TFC Engineering for                
          "sales and organizing the mobile homes, making collections,                 
          taking care of repairs, also leasing the mobile homes--taking               
          care of all those things for you."  The documentary evidence                
          shows that during 1990 and 1991 petitioner wrote 17 checks to Ms.           
          Ridgway totaling $2,582, 16 of which appear to relate to certain            
          repair and other expenses regarding certain automobiles, one of             
          which for $1,100 contained the handwritten notation "Business",             
          and none of which establishes that those checks were payments for           
          services rendered during those years by Ms. Ridgway to petitioner           
          in the conduct of a business of purchasing, repairing, and re-              
          selling automobiles.  In short, we are not persuaded by Ms.                 
          Ridgway's testimony (and the other pertinent evidence) that                 
          petitioner was engaged in such a business during 1990 and 1991.             




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