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employees and no officers or directors. When clients obtained
petitioner’s services, they did not execute an engagement
contract with JJH, and the clients did not recognize JJH as the
service provider. JJH did not have a rental agreement for its
office space from Simmons; Simmons had a verbal agreement with
petitioner to rent the entire house to petitioner. JJH did not
engage in a business activity.
Charlene made fabric and wood country crafts that she sold
to craft malls. Petitioner and Charlene incorporated Char’s
Country Accents, Inc. (CCA), in 1986 to operate this business.
Charlene and Craig were the owners and officers. CCA’s address
and location were at the Muehl residence.
In 1987, petitioner incorporated an entity he called Coastal
Leasing (Coastal) to conceal his assets from the Service.
Coastal’s address was the Muehl residence. Coastal did not
conduct any business activity, and petitioner used Coastal to
circulate funds among and between his other entities and his
family members. By 1994, petitioner allowed Craig to operate his
construction activities under the Coastal name to give the
appearance that Craig was a mature individual with his own
construction company.
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Last modified: May 25, 2011