Sam F. Ford and Ingrid D. Ford - Page 19

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          also establishes that Ms. Ford played an integral part in this              
          understatement of income.                                                   
               Ms. Ford testified that she had no knowledge of the                    
          understatement, but she owned several of the nominee corporations           
          at issue in this case.  She also recognized the corporate names             
          of Pooh Bear Investments, Ltd.; Bear & Pebbles Investments, Ltd.;           
          For Door Investments, Ltd.; and Solar Aquafarms, Ltd.  Ms. Ford’s           
          recognition of these names and their history (she testified that            
          For Door was a combination of the names Doorn and Ford, and that            
          Pooh Bear as well as Bear & Pebbles was named for petitioners’              
          dogs) makes her testimony that she had no knowledge of Mr. Ford’s           
          activities less than credible.  The Court concludes that Ms. Ford           
          had knowledge of, and involvement in, the fraudulent financial              
          transactions of 1986.  This factor weighs against petitioners.              
               2.   Maintenance of Inadequate Records                                 
               Lack of records is indicative of fraudulent intent.  Id.               
          Mr. Ford acknowledged during his testimony in this case that                
          petitioners kept few records as to the subject transactions.  The           
          “records” in this case consist of handwritten letters, some                 
          canceled checks, a few banking records from domestic and                    
          international accounts, and a stock option exercise agreement by            
          Ms. Ford.  Those records show direct control and management of              
          the Canadian accounts by both petitioners.                                  
               This factor weighs against petitioners.                                






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