Edward D. Lang and Sharon A. Lang - Page 13




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          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                       








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