Zabetti A. Pappas - Page 20

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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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