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1984, she testified that she did not recall a relationship with
the company. She further claimed that she was not aware of Mr.
Ford’s criminal charges until sometime after his Fatico
sentencing hearing.
Ms. Ford testified that she did not read the question on
Schedule B of the return which asked whether she had an interest
in, or signature or other authority over, a foreign bank account,
and she could not confirm whether the question was answered
truthfully. The record evidence shows that she did have several
bank and brokerage accounts overseas in 1986, and she even
admitted in testimony that she had a bank account at TSB Private
Bank International S.B. in Luxembourg. Ms. Ford’s testimony was
not truthful. She testified, under oath, that she had no
financial experience, but she did. She testified under oath that
she never looked at anything her husband gave her to sign, but
she did—she later admitted that she knew the names of the nominee
corporations and even from where they were derived. She stated
on the 1986 return that she had no overseas bank accounts, but
she did. The Court finds Ms. Ford’s testimony inconsistent and
implausible because her claims of ignorance are not credible when
viewed against her complex and numerous financial dealings in
1986.
This factor weighs against petitioners.
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