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until 4 months after this alleged meeting, and the notations
indicate that the meeting involved only petitioner, Archie McGill
as director, and petitioner wife as vice president. The
notations for another trip, this one to Hawaii in June 1994, also
indicate various business meetings related to Search2000 took
place. However, these alleged business meetings occurred solely
between petitioner and petitioner wife over hotel dinners.
Certain receipts and invoices petitioners provided do
reflect likely trade or business expenses. However, the expenses
that were billed to Navis clearly were incurred by Navis rather
than petitioners. We further conclude that the other business-
related expenses that reflect petitioner or petitioner wife as
the purchaser or payor also were expenses of Navis rather than a
sole proprietorship of petitioner. Petitioner held himself out
as the CEO of Navis in his business dealings, and the evidence of
business activities in the record reflects that the activities
were those of Navis rather than of petitioner as a sole
proprietor. Other than petitioner’s testimony, there is no
evidence in the record supporting his contention that he was
conducting his business activities as a sole proprietor--whether
such a business was as a venture capitalist, as petitioners
argue, or another activity--and that Navis was a mere “shell”
that conducted no business. We do not accept petitioner’s
testimony because it is self-serving, uncorroborated, and
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