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iv. Explanations of Behavior
Petitioner testified that he did not organize CAI, was not a
shareholder or beneficial owner of CAI, did not have a working
knowledge of CAI, and did not have authority to direct
disbursements from CAI. Petitioner testified that he was led
astray by Finley Kumble as to the organization and operation of
CAI. Petitioner testified that Finley Kumble organized and
operated CAI for Finley Kumble's personal gain. Petitioner
testified that he never sought legal advice on the organization
or operation of a foreign corporation, and that he did not
receive any related advice from, or attend any related meeting
with, Finley Kumble on this subject.
The record contains substantial evidence that rebuts
petitioner's testimony. The record adequately demonstrates that
petitioner sought legal assistance concerning his attempt to
minimize his Federal income taxes with respect to the subject
commissions; that he was actively involved in CAI's organization
in an attempt to minimize his Federal income taxes; that he owned
50 percent of CAI; that he directed the payment of his personal
commissions to CAI, which he knew to be nothing more than a
"paper corporation"; that he instructed Mr. Quin to withdraw
funds from CAI for his (petitioner's) benefit in an evasive and
surreptitious manner; that the funds withdrawn from CAI were not
loans to him; that he knew he had a tax problem with respect to
the commissions; that he knew that the commissions were never
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