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Ivory Land, Inc. (Ivory Land) was incorporated in the State
of Nevada on August 6, 1986. Petitioner was its president,
secretary, treasurer, and director. This corporation was a
nominee corporation for petitioner.
An additional corporation, 77 Ivory Corp. (77 Ivory), was
incorporated in the State of New York on April 21, 1976, and was
a nominee corporation for petitioner.
Petitioner incorporated Ivory Tower Holding Corp. (Ivory
Tower) in the State of New York on August 26, 1977. Ivory Tower
was established as a holding company for all of petitioner's
other companies and was a nominee corporation for petitioner.
Ivory Land, Ivory Ranch, 77 Ivory, and Ivory Tower did not
file corporate Federal income tax returns for the years in issue.
During the years in issue, petitioner signed sale contracts,
deeds, lease agreements, and numerous other related documents
needed to complete her business transactions, and on some
occasions authorized Mr. Freidus to sign them on her behalf.
Beginning in the 1970s, petitioner employed Edmund Burns
(Burns) to handle her real estate matters. Petitioner
subsequently made Burns her general counsel for all of her
business transactions.
On a number of occasions, Burns received proceeds from the
sales of petitioner's assets. Burns deposited these proceeds in
his law firm's client escrow account, along with deposits from
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