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by these companies to him. Petitioner had access to the funds
through his signatory powers over the accounts. He withdrew
moneys from the WHIP and Bank of America accounts to which the
Lockheed sums were paid. Such withdrawals exceeded $2.9 million.
He had access to the deposits made to All Patents' account at the
Banque de Paris, and he transferred funds from that account to
the Diesel Power account. He also had payments made in the name
of All Patents deposited directly to Diesel Power's account at
the Banque de Paris. He had signatory authority over the
accounts. Diesel Power provided no services to Lockheed and
Ashland from 1972 through 1976.
As a part of his effort to conceal the commissions earned
from Lockheed and Ashland and the interest income earned on the
accounts at Barclays Bank Bahamas and FNCB London, petitioner
concealed this information from Mr. Giffin, his accountant and
return preparer. This is evidence of fraud. Korecky v.
Commissioner, 781 F.2d 1566, 1569 (11th Cir. 1986), affg. T.C.
Memo. 1985-63. Mr. Giffin had instructed CTC's employees to
include all income and disbursements of CTC and petitioner,
whether business or personal, on CTC's cash receipts and cash
disbursements journals. Mr. Giffin relied on the journals in
preparing petitioner's Federal income tax returns. If items did
not appear on the journals, Mr. Giffin was not aware of them. No
commission payments that petitioner directed to the foreign bank
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