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lending businesses by entering data on a personal computer in
petitioner’s basement.
B. Petitioner’s 13 Corporations
Petitioner established the following 13 corporations: Best
Medicare of Brighton, Big John Cab Corp., Centurion Taxi, Inc.,
Collie Trans. Corp., Downey Cab Corp., D & S Jewelry Corp., Egret
Trans. Corp., Eleemosynary Cab Corp., Juice Taxi Co., Inc., Macar
Service Corp., Oxus Taxi Inc., Poodle Trans. Corp., and Tree Top
Cab Corp. (the 13 corporations).
Petitioner had accounts at Republic National Bank of New
York (Republic Bank) for the 13 corporations. The mailing
address for the 13 corporations was petitioner’s home.
Petitioner was a stockholder in, and officer of, all of them.
The 13 corporations did not do business, maintain books and
records, hold annual meetings, issue financial statements, pay
salaries or dividends, have employees, or file Federal or State
corporate tax returns.
When petitioner established the 13 corporations, he used
employer identification numbers (EINs) of former clients or
numbers that he created. He did not obtain EINs for the 13
corporations from the Federal government. At the time of trial,
Wolfson did not know the names of any of the 13 corporations.
Petitioner deposited amounts that he earned into the bank
accounts for the 13 corporations. Republic Bank paid interest on
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