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an officer of Real Services. Moreover, Mr. S. testified that he
was not involved in the directorship or management of Real
Services. Although Laura C. provided some testimonial support to
petitioner’s claims of corporate meetings and elections, we
believe that her testimony was coached and does not accurately
represent actual events.
There is no evidence of any business extending credit to
Real Services; for example, its name did not appear on any of the
documents used for its alleged leasing of real properties.
Indeed, the contrary appears to be true: on the E. 65th Street
apartment, the name of the lessee was Jane M., not Real Services,
and on the E. 77th Street apartment, the name was that of Joy C.,
not Real Services. Similarly, the lease for the W. 58th Street
apartment does not indicate that the lessor-sublessee was Real
Services.
Real Services’ alleged dealings in the Hawaii real property
are similarly suspect. These arrangements were made with
petitioner’s family members. Once again, many of the documents
executed in these transactions bear only petitioner’s name, and
not that of Real Services.
In sum, there is no evidence that Real Services engaged in
business as a separate entity. Petitioner cites clauses
typically used in preprinted forms for incorporating business
entities. The use of such clauses for Real Services, however,
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