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his failure to include income of more than $2.8 million from the
sale of securities. Petitioners conceded during this case that
this unreported income of more than $2.8 million was not included
in the notice of deficiency.
Mr. Ford used Marc Ford’s name in many of petitioners’
financial transactions. During 1985 and 1986, Mr. Ford had
access to bank accounts which were opened under the name of Marc
Ford, and he wrote checks from those accounts. Mr. Ford owned
assets in Marc Ford’s name and opened brokerage accounts in Marc
Ford’s name. During 1986, Mr. Ford owned, in Marc Ford’s name,
shares of International Tillex and Beverly Development.
VIII. Ms. Ford’s Financial Transactions
Ms. Ford signed many financial documents relating to these
transactions, including some relating to ownership in shares of
International Tillex. In 1986, she had multiple brokerage
accounts and bank accounts in her name and signed documents
relating to them.
During 1986, Ms. Ford purchased several items for large
amounts of money. For instance, she purchased fur coats costing
approximately $17,000 from the Pappas Fur Co. in British
Columbia. On or about April 30, 1986, she purchased a 1986
Rolls-Royce from Gregg Motors Rolls-Royce of Beverly Hills,
California, for $114,736.80, which she paid by checks in the
amounts of $100,000 and $14,899.50.
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