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falls short of showing actual business activity by the
corporation. Nor is such activity reflected in petitioner’s
practice of having salespeople and customers use the name “Real
Services” when they executed sales slips and checks to
petitioner. The fact remains that no one who dealt with
petitioner did so with any reliance upon the business probity or
solvency of Real Services. To the extent that anyone acquiesced
in petitioner’s employment of the name “Real Services”, they did
so with the understanding that they were doing business with her,
and not with a corporation.4
We conclude that Real Services functioned merely as an alter
ego of petitioner and is therefore a sham corporation. As a
result, we disregard the existence of Real Services for purposes
of Federal taxation; the income at issue is properly taxed to
petitioner individually.
II. Whether Petitioner Had Unreported Income From an Escort
Business in 1989 and 1990
Petitioner operated an escort business as previously
described during 1989 and 1990. Although she denies involvement
with the escort business, and with the receipt of income from
4 In this regard, petitioner argues that the dealings of
Real Services involved making payments to a puppeteer. In
support she cites an exhibit that was not introduced into
evidence. She has made similar citations throughout her briefs.
These documents are not part of the record and have not been
considered in making our decision herein. Rule 143; see
Eickmeyer v. Commissioner, 66 T.C. 109, 110 n.3 (1976).
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