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were filed. There is, however, ample evidence in the record to
conclude that Mr. de Bruijn was intimately involved in the daily
workings and affairs of the corporation, regardless of his lack
of official title. Moreover, the record shows that Jacques de
Bruijn was authorized to act on behalf of and to protect the
interests of Starvest in its tax matters for the years at issue.
Jacques de Bruijn served as Starvest's president, secretary,
and treasurer, and as one of Starvest's directors from the
company's inception in 1987 until 1996. Officer and director
changes were formally made at Starvest in 1996, and Mr. de Bruijn
ceased to have any official title with the corporation.
Starvest's new officers and directors were all foreign nationals
domiciled outside of the United States. Mr. de Bruijn continued
to represent the company and look after its affairs on a daily
basis despite the management changes.
Starvest's president, Mario Boon, signed a Tax Information
Authorization vesting Jacques de Bruijn with authority to receive
and inspect confidential information relating to Starvest's tax
matters for its 1992 through 1996 tax years. Mr. de Bruijn acted
as Starvest's representative during the IRS audit of the
corporation. Starvest's officers and directors did not have any
contact with the IRS or involvement in the handling of the audit.
When the notices of deficiency were issued, de Bruijn retained
legal counsel to protect the corporation's interests.
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