Walter L. Medlin - Page 57

                                       - 142 -                                        
               There is considerable evidence of the concealment of assets            
          and of income for the tax years at issue, and we find that this             
          concealment is due in large part to an intent to mislead tax                
          authorities and to evade taxation on income.91  For the years               
          1981 through 1990, petitioner had his personal residence titled             
          in the name of Mr. Miles, as trustee.92  Also, in 1987,                     
          petitioner purchased a Ferrari and had the bill of sale and the             
          application for a temporary tag put in the name of Mr. Miles’s              
          law firm.  Petitioner regularly used Mr. Miles, Ms. Allen, and              
          other trustees to hold and sell his various properties, and he              
          then used Mr. Miles’s law firm’s trust account to hold the                  
          proceeds from the sales.  The trustees had no functions other               
          than holding title to the properties, and petitioner was firmly             
          in control of the proceeds that passed into the law firm’s trust            
          account.  Indeed, as trustee of that account, Mr. Miles did                 
          whatever petitioner instructed him to do, and petitioner                    
          requested on several occasions that Mr. Miles or Ms. Goodman pay            
          his personal expenses with his trust funds.  The use of nominee             
          accounts; i.e., the use of bank accounts fashioned as trust                 


               91Petitioner’s concealment of the various real estate                  
          transactions was so prevalent that respondent’s revenue agent was           
          able to discover those transactions only by a search of various             
          courthouse records in seven different counties.                             
               92We also note that on petitioner’s Forms 1040 for 1985-               
          1988, he lists his address as “P.O. Box 383, Lake Lure, NC                  
          28746”.  However, petitioner resided in Osceola County,                     
          Kissimmee, Florida, during the tax years at issue and at the time           
          of filing his returns.                                                      




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