Jacob R. Ramsburg, Jr. and Norma J. Ramsburg - Page 24

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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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