- 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 possiblePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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