- 21 -
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.
Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 NextLast modified: May 25, 2011