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which petitioner deducted as commissions paid on Schedule C of
his 1985 tax return. Petitioner deducted the costs of his
subscriptions to Playboy and Penthouse magazines on his 1986 tax
return as Schedule C business expenses.
The trusts that petitioner used did not file tax returns for
any of the tax years at issue. During 1985-88, petitioner never
informed Mr. Miles that petitioner believed that he had no
obligations to report his earnings from the trust transactions,
because they supposedly involved tax free exchanges.
Petitioner used the fictitious names “John Waltin”9 and
“William R. Wright” in some of his real estate transactions
during the tax years at issue. Petitioner signed various real
estate documents as “William R. Wright”. Petitioner signed that
name as a notary public on real estate documents and on articles
of incorporation filed with the State of Florida. Petitioner
used and signed the name “D.W. Davis” to purchase and sell real
estate. He opened a bank account in that name without the
knowledge of Mr. Davis. At one time, petitioner was a notary
public in the State of Florida; however, his license expired.
Petitioner continued to notarize documents after his license
expired.
9At trial, petitioner claimed that the name John Waltin was
not a fictitious name because “there’s probably a John Waltin
somewhere.”
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