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They formed four other entities in the mid-1980's named Colt
Tool & Die, Inc. (Colt), Synchronized Design & Development, Inc.
(Synchronized), Sovack Partnership (Sovack), and Jaclyn Leasing,
Inc. (Jaclyn) (we sometimes use the term “Zachova entities” to
refer to two or more of the six entities formed by petitioner and
Sova). Colt is a tool and die business, and its stock is owned
equally by petitioner, Sova, and Sova’s brother. Synchronized
designs the dies used by the Zachova entities, and its stock is
owned equally by petitioner, Sova, and Mark Bartolomucci. Sovack
owns the machinery and equipment used by Tool & Die and
Industries and the building in which those two companies operate;
Sovack is owned equally by petitioner and Sova. Jaclyn rents a
building to the Zachova entities; Jaclyn is owned equally by
petitioner and Sova.
Petitioner and Sova devised a scheme in or around 1983 to
obtain cash surreptitiously from Industries and Tool & Die.
Under this scheme (the false invoice scheme), third parties
issued false invoices to Tool & Die and Industries for work not
actually performed, Tool & Die and Industries paid the third
parties the amounts shown on the invoices, the third parties
returned the payments to petitioner and Sova net of a 25-percent
“commission”, and petitioner and Sova split the net payments
equally. Petitioner and Sova each received $217,162 from the
false invoice scheme in 1985, and they each received $94,439 from
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Last modified: May 25, 2011