- 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.Page: Previous 132 133 134 135 136 137 138 139 140 141 142 143 144 145 146 147 148 149 150 151 Next
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