- 12 - 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, andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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