William S. Fairey, Jr., and Susan R. Fairey - Page 26

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          and a letter from Brune to Hughs saying that the letter from                
          Special Friends to petitioner referred only to the golf clubs and           
          that Special Friends did not accept Visa payments.  Colanino                
          reviewed the files of Special Friends and found no record that              
          petitioner had contributed anything to Special Friends other than           
          golf clubs.  Second, the program in which petitioner purportedly            
          bought an advertisement did not include an advertisement relating           
          to him or acknowledge his purported contribution.                           
               Petitioners contend that respondent should have called Brune           
          to testify instead of Colanino.  We disagree.  Respondent                   
          reasonably called Colanino because he was the founder and                   
          executive director of Special Friends.                                      
               Petitioners contend that Colanino is not credible because he           
          received compensation from Special Friends.  We disagree.  The              
          fact that Special Friends paid annual compensation to Colanino              
          does not detract from his credibility.                                      
               Petitioners seek to discredit a letter from Omaha State Bank           
          stating that Special Friends did not accept credit card payments.           
          They contend that the letter is not credible because Colanino did           
          not authenticate it.  We disagree.  Colanino testified that                 
          Special Friends had an account with Omaha State Bank and that               
          Special Friends never used credit cards.  Petitioners also                  
          contend that Omaha State Bank was not the bank for Special                  
          Friends because it was not mentioned in the Special Friends golf            






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