Janet N. Drummond - Page 10




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          ing, inconsistent, and implausible statements to respondent's               
          agents about why he failed to report certain income in his 1983             
          return and why he reported no income in his 1984 return.  One               
          explanation that Mr. Drummond gave to respondent's agent for his            
          unreported income for the years at issue related to Harbour                 
          Marine Services in which Mr. Drummond had invested $25,000 during           
          1982.  Mr. Drummond told respondent's agent that Harbour Marine             
          Services was a sole proprietorship, which might have losses for             
          1983 and 1984 that would offset any income that he had for those            
          years.  At various times, Mr. Drummond told respondent's agent              
          that Harbour Marine Services had losses for 1983 in the amounts             
          of $47,000, $70,000, and $400,000.  Although Mr. Drummond in-               
          formed respondent's agent that Harbour Marine Services was a sole           
          proprietorship, he knew that it was a corporation because, inter            
          alia, (1) Harbour Marine Services had filed articles of incorpo-            
          ration with the California Secretary of State in 1982; (2) Mr.              
          Drummond had offered stock in Harbour Marine Services to an                 
          individual; (3) Mr. Drummond opened a corporate bank account for            
          Harbour Marine Services and listed himself as its president; and            
          (4) Harbour Marine Services' books were maintained as a corpora-            
          tion.  Moreover, on April 24, 1995, over two years after Mr.                
          Drummond was convicted under section 7206(1) of filing false                
          returns for 1983 and 1984, he presented respondent's agent with a           
          copy of Form 1120, U.S. Corporation Income Tax Return, dated                





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