- 20 - apartment she had rented, and then revealed a familiarity with minute details regarding the proceeding when cross-examining witnesses. In addition, on at least one occasion petitioner sought to have a document admitted into evidence that she had falsified. A witness testified credibly that petitioner provided him with a written statement that contained a material misstatement. He corrected the document and then signed it. Petitioner then substituted a page of that document which failed to reflect his correction before she submitted the document to this Court. We accordingly give credence to petitioner’s testimony and proffered documentary evidence only where we are convinced by independent corroborating evidence of their veracity or authenticity. I. Whether Amounts Paid to or Received by Real Services Are Properly Treated as Petitioner’s Taxable Income The first issue to be addressed concerns the identity of the taxpayer. Petitioner contends that she, individually, is not liable for the taxes at issue; instead, she argues, the corporation Real Services is liable for any taxes that may be owing, because Real Services received the unreported income that respondent has attributed to petitioner in his determination. Taxpayers have the right to shape business transactions in a manner that minimizes the incidence of taxation. Gregory v. Helvering, 293 U.S. 465, 469 (1935). In this regard, a corporate entity is deemed to exist as a separate taxpayer if it isPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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