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transaction report), both punishable by imprisonment in excess of
1 year. Fed. R. Evid. 609; see Lovell & Hart, Inc. v.
Commissioner, 456 F.2d 145, 148 (6th Cir. 1972), affg. per curiam
T.C. Memo. 1970-335; Tokarski v. Commissioner, 87 T.C. 74, 77
(1986) (we need not rely on uncorroborated testimony).
2. Lack of Corroboration for Petitioner's Claim That
He and Dogwood Acres Had a Joint Venture
The closing agent paid $250,000 to petitioner as a
commission for the Holiday Isle transaction. None of the Holiday
Isle transaction documents refer to Dogwood Acres. Petitioner
offered no documents to corroborate his affidavit or details
about the alleged joint venture. There is no other evidence that
Dogwood Acres was involved in the Holiday Isle transaction. None
of the parties to the Holiday Isle transaction (except
petitioner) thought that Dogwood Acres was involved. Dogwood
Acres did not report any of the $250,000 commission as income.
Petitioner contends that the alleged joint venture between
him and Dogwood Acres was an arm's-length transaction in which he
engaged with the advice of tax professionals. There is no
evidence that petitioner's dealings with Dogwood Acres were at
arm's length. All of the owners of the stock of Dogwood Acres
were members of petitioner's family.
Petitioner contends that Dogwood Acres received $175,000
($100,000 from petitioner and $75,000 from Saudi Corp.) of the
$250,000 as part of the consideration for services that he
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