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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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