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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 is
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