- 13 -
Respondent contends that this shows that petitioner knew about
the engineering income. We disagree.
Petitioner testified that he owned 50 percent of the
outstanding shares of Rapid Manufacturing, a corporation that
sold materials to DFIC. Petitioner asked to have a sign with
Rapid Manufacturing’s name on it installed at the DFIC plant to
help Rapid Manufacturing. Petitioner did not connect DRD to
DFIC.
Respondent’s agent testified that DRD owned DFIC. She said
that DRD became a partner in the DFIC partnership, but she did
not say when that occurred. She then vaguely suggested that
petitioner was involved with DFIC, without describing how, except
through her belief that DRD owned DFIC. Respondent cites Exhibit
104-R to support the claim that DRD owned DFIC. Exhibit 104-R is
a diagram that respondent’s agent prepared which was not admitted
into evidence. Respondent’s argument about the Rapid
Manufacturing sign is at best speculation, and it is not more
persuasive than other evidence showing that petitioner did not
know about the engineering income.
4. Capital Contributions
Respondent contends that Trisch’s contribution to DRD was to
perform engineering services and that petitioner’s contribution
was to provide capital. While that might be a possible
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011