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of deficiency for the taxable year 1986, are the identical
shares of Tillex and Beverly Development stock which Marc
Ford purportedly sold in 1986.
The circumstantial evidence linking petitioner Sam
Ford's admitted unreported income for the year 1986 in
excess of $2.8 million from the sale of securities he
secretly held in the names of such nominees as Marc
Ford, the Tillex and the Beverly Development stock
purportedly sold in 1986 by Marc Ford when it belonged
to petitioner Sam Ford, and the capital gains
adjustment for the disposition of the Tillex and the
Beverly Development stock in the statutory notice is
compelling.
In that response, respondent also listed five items of
circumstantial evidence to which respondent referred above. The
first item is petitioner's admission in his allocution that he
had failed to report income of $2.8 million "which I had secreted
in the name of my son and others." The second item is a
probation officer's report indicating that between 1984 and 1987
petitioner received "income from the sale of shares of Tillex
stock which netted $2,500,000 in profits." The third item is the
adjustment for capital gains contained in the statutory notice of
deficiency indicating that petitioners had failed to report
capital gains from the sale of stock in Tillex and Beverly
Development in the total amount of $5,084,483, with a resulting
increase in taxable income of $2,341,878. The fourth item is
respondent's indication that, at the trial of the instant case,
petitioner's son Marc Ford would testify that he sold stock in
Tillex and Beverly Development during 1986 for a net gain of
$2,807,704. The fifth item was a citation of petitioners'
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