- 17 - * * *. These people [Charlene and Craig] don't understand what's going on. They're part of it, they benefit from it, and they don't understand”. Charlene’s testimony corroborates petitioner’s admission as she was obviously unfamiliar with JJH. Charlene did not know what JJH’s assets were, and she had no idea whether it operated at a profit or loss. What Charlene did know about JJH was that it had a checking account from which she could withdraw funds. Her knowledge about JJH’s affairs stopped there. Craig knew even less about JJH, admitting that he does not recall how or why he became an officer and that petitioner just said “this is what we’ll do”. Petitioner’s attempt to lend legitimacy to the arrangement by naming his family members as officers of JJH is unavailing. JJH did not contract with Simmons for rental of the Muehl residence; petitioner did, and Simmons believed the rent checks were personal payments from petitioner. Petitioner prepared Simmons’ tax returns, and Simmons considered petitioner individually his “tax person”. JJH did not have services or utilities (e.g., telephone and electric) billed in its name, and there is no other credible evidence that it contracted with third parties or held itself out to the public as a business. The only activity in which JJH engaged was receiving, spending, and circulating the funds earned by petitioner. JJH was essentially a conduit through which petitioner moved funds. PetitionerPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
Last modified: May 25, 2011