Sam F. Ford and Ingrid D. Ford - Page 23

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               5.   Concealment of Income or Assets                                   
               Concealing income or assets is indicative of fraud.                    
          Bradford v. Commissioner, 796 F.2d 303 (9th Cir. 1986).  Mr. Ford           
          admitted under oath that he “secreted” securities belonging to              
          him “in accounts in the name of my son and others.”  Further                
          examination by respondent uncovered money hidden in Canadian                
          brokerage accounts which respondent determined belonged to                  
          petitioners.  Ms. Ford played a critical role in Mr. Ford’s                 
          concealment of assets, taking sole title to their Montecito home            
          and to their Rolls-Royce.  She also was listed as the owner of              
          several of the nominee corporations at issue, and she owned in              
          her own name many investments, including shares of International            
          Tillex.  Had these assets been owned by Mr. Ford, he would have             
          been unable to represent to the SEC that he owned no stocks or              
          bonds, that he had gross income of $16,000 in 1985, that he had a           
          net worth of negative $560,000 throughout 1985 and 1986, and that           
          he was unemployed and trying to avoid filing for bankruptcy.                
               On the basis of Mr. Ford’s own testimony and upon the                  
          evidence before the Court, the Court concludes that petitioners             
          concealed assets from the SEC and from respondent.                          
               Ms. Ford played a sophisticated role in petitioners’                   
          concealment of assets; she was not financially naive.  Her                  
          testimony to the contrary is flatly contradicted by all the                 
          evidence before this Court.  In 1986, she was a business partner            






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