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prepared the subject returns relying upon that information.
Roach did not tell Jung that, during the subject years, the
Centurion sailed in the Ensenada, Puerto Vallarta, and beer can
races, that individuals slept on the Centurion, and that
individuals fished on board the Centurion; Jung believed
otherwise as to each of these matters. Jung also was not told
about the individuals who were on board the Centurion during the
relevant years. Roach told Jung that the Centurion was used by
petitioner as a conference/meeting room for its staff and as a
place to write, and Roach led Jung to believe that Roach simply
met individuals on board the Centurion while it was moored at the
yacht club. Roach also led Jung to believe that meals were not
eaten on board the Centurion.
Roach signed under penalties of perjury 1998 and 1999
property tax statements for the Centurion, and he submitted those
statements to the Office of Assessor for the County of Los
Angeles. Roach reported on the 1998 property tax statement that
the Centurion’s use was “recreation”. Roach reported on the 1999
property tax statement that the Centurion’s use was “pleasure”.
OPINION
1. Court’s Perception of Petitioner’s Witness Roach
Petitioner’s primary witness at trial was Roach. On the
basis of our view of Roach when he testified, as well as on the
basis of our consideration of his testimony in the light of the
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