Dale H. Sundby and Edith Littlefield Sundby - Page 13

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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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