- 19 - also establishes that Ms. Ford played an integral part in this understatement of income. Ms. Ford testified that she had no knowledge of the understatement, but she owned several of the nominee corporations at issue in this case. She also recognized the corporate names of Pooh Bear Investments, Ltd.; Bear & Pebbles Investments, Ltd.; For Door Investments, Ltd.; and Solar Aquafarms, Ltd. Ms. Ford’s recognition of these names and their history (she testified that For Door was a combination of the names Doorn and Ford, and that Pooh Bear as well as Bear & Pebbles was named for petitioners’ dogs) makes her testimony that she had no knowledge of Mr. Ford’s activities less than credible. The Court concludes that Ms. Ford had knowledge of, and involvement in, the fraudulent financial transactions of 1986. This factor weighs against petitioners. 2. Maintenance of Inadequate Records Lack of records is indicative of fraudulent intent. Id. Mr. Ford acknowledged during his testimony in this case that petitioners kept few records as to the subject transactions. The “records” in this case consist of handwritten letters, some canceled checks, a few banking records from domestic and international accounts, and a stock option exercise agreement by Ms. Ford. Those records show direct control and management of the Canadian accounts by both petitioners. This factor weighs against petitioners.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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