James O. Jondahl - Page 10

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         least $190,240 to Taxman. Petitioner controlled the amounts that             
         WFIC transferred to Taxman.                                                  
              On November 26, 1990, WFIC registered the trade name “Epic              
         Real Estate” with the State of North Dakota.  In 1990, petitioner            
         inquired of the NDREC whether it was permissible for him to                  
         advertise under the name Epic Real Estate as a division of WFIC.             
         He was informed that it was, but that he could not advertise                 
         solely as Epic Real Estate while operating through a corporation.            
         In a letter dated February 19, 1992, petitioner informed the                 
         secretary of the NDREC that “Epic Real Estate” would no longer be            
         a division of WFIC but a sole proprietorship under petitioner’s              
         broker’s license.  On February 19, 1992, petitioner filed an                 
         official notice of change of address and name with the NDREC,                
         showing a change of business name from “West Fargo Investment                
         Corporation d/b/a Epic Real Estate” to “Epic Real Estate”.  Also             
         in February 1992, petitioner changed the name on WFIC’s trust                
         account, without the knowledge or approval of WFIC’s shareholders            
         or directors, from “West Fargo Investment Corporation d/b/a Epic             
         Real Estate” to “James O. Jondahl d/b/a Epic Real Estate”.                   
         Petitioner renewed his broker’s license for 1993 using the name              
         “Epic Real Estate”.  On September 24, 1993, petitioner changed               
         the business name with the NDREC back to “West Fargo Investment              
         Corporation d/b/a Epic Real Estate”.                                         







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