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From 1988 through 1995, petitioner’s primary residence was
located in Germany, but petitioner also maintained a rental
residence in Garland, Arkansas.
Between 1988 and 1993, petitioner and Garland Farms, Inc.
(Garland Farms), another Arkansas corporation that petitioner
established and that petitioner also appears to have controlled,
acquired a number of farm properties located in Arkansas and
Louisiana for the purpose of dividing the properties into smaller
parcels and leasing the properties to farmers (tenant farmers),
which in fact occurred.
Petitioner was the initial president of Garland Farms. The
sole direct shareholder of Garland Farms apparently was Bitola
Co. Establishment (Bitola), a Liechtenstein corporation, the
stock ownership in which was not credibly established at trial.
In July of 1988, Alexander Frick nominally became the
president of Garland Farms, but Frick simultaneously executed a
power of attorney on behalf of Garland Farms authorizing
petitioner to control and operate Garland Farms, under which
power of attorney petitioner also had the power to control the
funds of Garland Farms. Frick did not testify at the trial.
During the years 1988 through 1996, various employees of Garland
Farms regarded petitioner as the owner and/or general manager of
Garland Farms.
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