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and not a business purpose, that only one signature was to be
required in order for withdrawals to be made from the account,
and that the account owner was a trust.
In the case of an account’s being opened for a trust as
owner of the account, the account application requested informa-
tion as to the names and the addresses of the beneficiaries of
the trust and whether the trust was a revocable trust or whether
it had a pay-on-death designation. Mr. Barmes did not provide
that information on any of the account applications that he
completed.
In a section marked “BACKUP WITHHOLDING CERTIFICATIONS”, the
account application requested that the account owner certify
under penalties of perjury that the TIN provided on the applica-
tion was the correct TIN for that account owner and, if applica-
ble, that the account owner certify that such account owner was
not subject to backup withholding, was an exempt recipient,
and/or was a nonresident alien. In each account application, Mr.
Barmes indicated on behalf of the account owner, which in each
instance he claimed was a trust, that the TIN provided in such
application was the correct TIN for the trust, that the trust was
not subject to backup withholding, and that the trust was not a
United States person. Mr. Barmes signed each of the account
applications that he completed under penalties of perjury,
thereby certifying under such penalties that the foregoing
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