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corporation, to engage in shipping. Petitioner is the president
of and is now a consultant for Bohannon, S.A. He has otherwise
retired from active participation in the corporation.
Petitioner became a minority shareholder in Bohannon, S.A.
in the mid-1960's. He owned bearer shares in Bohannon, S.A. that
he later sold to the corporation.
Bohannon, S.A. owned ships. It did business worldwide,
including hauling grain from Texas to Australia, hauling
wastepaper, and transporting dry cargo. It did business mainly
in Europe and North America. Company accountants kept records of
Bohannon, S.A.'s income.
Bohannon, S.A. had a bank account in Panama. Petitioner had
signature authority on the account.
Petitioners first reported that they sold Bohannon, S.A.
stock on their 1982 return.
The United States invaded Panama on December 20, 1989.
C. Bob Wade Ford, Inc.
1. Organization and Ownership
Bob Wade Ford, Inc. (now South Lake Ford), a Ford dealership
in Clermont, Florida, was organized on December 1, 1970.
Clermont is about 20 miles west of Orlando. Bob Wade Ford sells
new and used cars. It opened used car lots in Bushnell, Florida,
in 1985, and Winter Garden, Florida, in 1986.
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