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records, including those from the Cayman Islands. Petitioner did
not produce any of the records.
In addition, a grand jury subpoena was served on the Bank of
Nova Scotia for the records relating to petitioner's bank account
in the Cayman Islands. Petitioner's Cayman Islands bank records
were not produced pursuant to this subpoena.
On July 28, 1983, petitioner removed all his funds at the
Bank of Nova Scotia in the Cayman Islands. Petitioner withdrew
$3,125,000 from his personal accounts and $486,000 from the
account of Cayman Aviation Finance, which petitioner considered
his money.
The funds petitioner withdrew from the Bank of Nova Scotia
were eventually deposited into petitioner's accounts at the Bank
of Credit and Commerce International (BCCI) in Panama City,
Panama. Petitioner's accounts at BCCI were interest-bearing
accounts. During 1985, 1986, 1987, 1988, and 1989, petitioner
earned interest on his funds deposited at BCCI in the amounts of
$271,383, $265,288, $214,074, $277,315, and $354,072,
respectively. Petitioner intentionally omitted the interest
earned on his money on deposit in Panama at BCCI from his 1985
through 1988 Federal income tax returns. Petitioner did not
report any of the interest he earned on the funds deposited at
BCCI during any taxable year.
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Last modified: May 25, 2011