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that Export was a strong, sturdy business. Further, according to
the articles of incorporation, Export was formed to sell American
manufactured products abroad and to enter into agreements with
manufacturers and distributors.
We are further satisfied that Export engaged in a sufficient
level of business activity. Petitioner held himself out to the
public as the president of Export, and petitioner attempted to
secure sales and purchases under the corporate name. Petitioner
sent several letters to various distributors and purchasers on
the Export letterhead in an effort to create business. In fact,
Export had one sale, although the sale was subsequently
cancelled. Export’s level of business activity for 1996 and 1997
was such that we will not disregard the corporate form.
Petitioner contends that the corporate form should be
disregarded because he spent only 3 to 4 hours per week on the
business. Petitioner, now recognizing it is advantageous to
disregard the corporate entity, testified that he engaged in
little or no sales activity, which is inconsistent with the
position in his Federal tax returns. For example, petitioner
claimed on those returns that he drove a total of almost 29,000
miles in 1996 and 1997 for business purposes. We are not
required to rely upon petitioner’s self-serving testimony. See
Niedringhaus v. Commissioner, 99 T.C. 202, 219-220 (1992);
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