Harold Wapnick - Page 17




                                       - 17 -                                         
          properly included in the jury instructions in petitioner’s                  
          criminal case).                                                             
               For reasons discussed next, we do not recognize the 13                 
          corporations for Federal income tax purposes.  Petitioner used              
          false EINs when forming the corporations.  The 13 corporations              
          did not follow any corporate formalities such as maintaining                
          books and records, issuing stock, holding annual meetings,                  
          electing officers, or issuing financial statements.  They did not           
          have employees, they paid no salaries or dividends, and they did            
          not conduct any legitimate business.  They did not file tax                 
          returns.  Petitioner did not treat the 13 corporations as                   
          separate business entities.  He often lent money from one                   
          corporate account and deposited repayments for that loan in other           
          corporate accounts.                                                         
               Petitioner contends that the 13 corporations provided tax              
          preparation, money lending, and check cashing services.  We                 
          disagree.  There are no documents in evidence that show there               
          were any business transactions between a client and any of the              
          corporations.  No checks payable to any of the 13 corporations              
          were produced at trial.  Petitioner’s clients made checks for               
          services payable to petitioner, H. Wapnick & Sons, or cash.                 
               Petitioner testified and contends that he did not own all of           
          the stock of the 13 corporations.  He contends that John Wapnick            
          and Seth Wapnick bought Centurion Taxi, Inc., at the end of 1987;           






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