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In * * * [petitioners’] 1986 federal personal income
tax return, I failed to include income in excess of
$2.8 million I had received from the sale of securities
belonging to me which I had secreted in accounts in the
name of my son and others. The income, however, was
reported on my son’s 1986 personal tax return and the
tax was fully paid through him. I had arranged for the
income to be reported on his income tax return
specifically to conceal my earnings * * * In short,
when I filed my 1986 federal personal income tax
return, I willfully made a return * * * knowing that
the return was not true and correct as to material
matters.
III. Canadian Stock Transactions
Mr. Ford’s criminal conviction had its genesis in the early
1980s, when Mr. Ford purchased and sold International Tillex
stock through Canadian brokerage accounts which were owned by at
least seven nominee corporations, namely: (1) For Door
Investments, Ltd.; (2) Pooh Bear Investments, Ltd.; (3) Bear &
Pebbles Investments, Ltd.; (4) Canadian American Aquafarms
International, Ltd.; (5) Solar Aquafarms, Ltd.; (6) Toronado
Resources; and (7) Blackbird Investments. Ostensibly, these
nominee corporations were owned by either Ms. Ford or Marc Ford,
but in reality, they were controlled by Mr. Ford. Each of these
nominee corporations traded in shares of International Tillex
and, later, Beverly Development. These nominee corporations
received income totaling more than Can$ 8 million from trading in
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