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fraud and was, at his counsel’s request, provided an opportunity
to file a brief. He failed to file a brief. The facts set forth
below are based on the matters deemed admitted and petitioner’s
testimony at trial.
Petitioner received a degree in finance in 1994 from the
University of South Florida. After receiving his degree, he
worked as a loan officer or mortgage banker at various companies.
Eventually, he started his own mortgage brokerage business known
as Colonial Mortgage Corp.
Prior to 1996, petitioner filed individual Federal income
tax returns prepared by a certified public accountant. In 1995,
petitioner purchased two Unincorporated Business Trust
Organizations (UBTOs) from abusive trust promoter Joseph Nelson
Sweet. The two UBTOs never filed income tax returns.
Petitioner did not maintain a personal checking account
during the years in issue. He deposited his personal income into
a bank account opened in the name of one of the UBTOs.
Petitioner was the sole signatory on the bank account.
During the years in issue, petitioner received unreported
income as follows:
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