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* * *. 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. Petitioner
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