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Testimonial Evidence
At the trial in this case, petitioners called Mr. Ramsburg,
Mr. Stottlemeyer, and Mr. Rippeon as witnesses. With respect to
the testimony of Mr. Ramsburg, we did not find him to be credi-
ble. In addition, we found Mr. Ramsburg’s testimony to be
evasive, uncorroborated, and/or self-serving in certain material
respects. We shall not rely on such testimony of Mr. Ramsburg to
establish petitioners’ position in this case.
With respect to the testimony of Mr. Stottlemeyer, we found
his testimony to be implausible, questionable, vague, conclusory,
and/or uncorroborated in certain material respects. We also
found Mr. Stottlemeyer’s testimony to serve in certain material
respects the interests of Mr. Ramsburg, who was Mr.
Stottlemeyer’s longtime friend from childhood and the owner of
Frederick Underwriters, Mr. Stottlemeyer’s employer, and who gave
Mr. Stottlemeyer the opportunity to be his partner in Kildare
Timmy. We shall not rely on such testimony of Mr. Stottlemeyer
to establish petitioners’ position in this case.
With respect to the testimony of Mr. Rippeon, one of the
certified public accountants employed by Keller Bruner to prepare
petitioners’ returns for the years at issue, Kildare Timmy’s
partnership returns, and the Keller Bruner checklists utilized in
preparing such partnership returns, Mr. Rippeon had no personal
knowledge about any of the underlying facts with respect to the
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