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explanations of behavior are a badge of fraud. Petitioner notes
on brief that the Pierpont Account was needed to prevent Mr.
Freidus from making unauthorized purchases on petitioner's behalf
at art auctions. However, this self-serving assertion is not
supported by the record.
Petitioner's use of nominee corporations is further evidence
of asset concealment. See Jones v. Commissioner, T.C. Memo.
1994-230, affd. without published opinion 68 F.3d 460 (4th Cir.
1995) (finding that a taxpayer's use of alter ego corporations to
conduct personal as well as business transactions was evidence of
asset concealment). The record shows that the corporate accounts
were mere repositories for proceeds derived from petitioner's
income producing activities. In addition to proceeds from sales
of her Golden Maharajah Diamond and Picasso Ceramics which were
deposited into the Ivory Land account, petitioner also deposited
proceeds from horse sales into the Ivory Ranch account. Since
petitioner's nominee corporations did not file returns, tracing
and attributing income to petitioner would be severely impeded.
Petitioner argues that the corporations were formed solely
to hold title to real property and to insulate her from personal
liability. Once again, petitioner's assertion is contradicted by
the record. The parties have stipulated that the corporate
accounts were used to pay petitioner's personal expenses.
Petitioner also used corporate funds to invest in fine art and to
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