Zabetti A. Pappas - Page 24

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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              
               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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