- 15 -
were significant risks, and that it was very likely that the
Commissioner would audit petitioner, Dr. Young, and/or one or
more of their related entities. Finley Kumble reiterated this
warning in a letter to petitioner dated December 15, 1980.
In the letter of October 27, 1980, Finley Kumble also
advised petitioner and Dr. Young that Form 959, Return by an
Officer, Director, or Shareholder with Respect to the
Organization or Reorganization of a Foreign Corporation and
Acquisition of its Stock, should be immediately filed with the
Commissioner to reflect the transfer of their contractual rights
to CAI. The letter explained that Form 959 must be filed by
persons holding an office (or serving as a director) of a foreign
corporation or owning 5 percent of its stock.
Finley Kumble prepared Forms 959 for petitioner and Dr.
Young. Finley Kumble gave petitioner his Form 959 at a meeting
in Bermuda, and he signed the form at that time. Petitioner
never filed this (or any other) Form 959, and he did not ask
Finley Kumble (and Finley Kumble did not assume the legal
responsibility) to file Form 959 on his behalf.
4. CAI's Interest Accounts
In addition to the C account, CAI had time deposit (TD)
accounts in which money was transferred from the C account to
Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 NextLast modified: May 25, 2011