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which respondent contends shows that the transaction was a sale.
We disagree.
Ms. Blair maintained this ledger. The ledger contained a
page captioned "S. Robert Davis - Strata". Ms. Blair testified
that the purpose of this page was to keep track of how much
Strata stock Mr. Davis owned. She further testified that she
made the entries in the ledger referencing the transfer of
100,000 shares of Strata stock to Mr. Walker and that the
transfer was not a sale of stock. Ms. Blair was credible, and
her testimony corroborates Mr. Davis' testimony.
Furthermore, Mr. Davis testified that he was always
promoting companies and that he made a practice of giving stock
to people or investors in order to encourage them to send other
investors to him or to keep them as investors. Mr. Walker was an
important investor and a source of investors, and we believe that
Mr. Davis made the gift to Mr. Walker in order to keep Mr. Walker
as a potential future investor and source of potential future
investors. Additionally, there is no evidence that petitioner
received any money from Mr. Walker for the Strata stock.
H. ODC
Respondent claims that petitioner fraudulently overstated
the value of the Strata stock he donated to ODC. Respondent
argues that the stock was unregistered, and petitioner's claimed
deduction was based on the registered, traded, asked price.
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