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the information and the claim that the loans were from Mexico
made it difficult to investigate.
Respondent substantiates her assertion of unreported income
with information on deposit slips and with petitioner's
statements that he was the owner of and had income from Cable
Leon on numerous documents, including the mortgage application
for the home in the Dominion, the Statement of Financial
Condition that petitioner prepared, the application to the Texas
Department of Banking, and the information provided in connection
with the attempted purchase of the shopping center. Petitioner
represented on various documents that he was the sole owner of
several other businesses and that he had substantial income from
Cable Leon.
Respondent's agent examined petitioner's bank accounts,
deposit slips, and the financial reports prepared by
G. Rodriguez. The source of the funds on the documents was often
left blank. At least one deposit slip showed the source of the
funds was Cable Leon. Respondent interviewed Boldt and
G. Rodriguez. Neither of them was aware of any loans from
Mexican companies or petitioner's wife.
Petitioner admits that the Mexican businesses exist. It is
his assertion, however, that the stock in the businesses is not
in his name. Petitioner testified that he is a playboy and that
his father did not trust him with the family fortune. He asserts
that his father put his share of the family assets into a Mexican
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