- 40 - Mr. Richardson also testified that he first received a referral fee from Aegis in March of 1996 for bringing an individual to meet with, and introducing him to, Mr. Bartoli in Chicago. The record is nebulous at best on the genesis of any activity on the part of HGAMC. The Form SS-4, Application for Employer Identification Number, stated that business started on April 1, 1996. The instrument that by its terms “created and established” HGAMC is dated August 17, 1996. Petitioners’ signatures on many of the documents pertaining to HGAMC and dated in August were notarized on December 3, 1996. Mr. Richardson’s testimony on this point was confused, if not contradictory, and in the midst of an unsuccessful colloquy attempting to reconcile various dates, he was able only to offer that HGAMC was “operated” before August 17, 1996. Given these circumstances, it cannot be said that the record bears out petitioners’ attempts to portray the establishment of HGAMC as working some sort of clean break in Mr. Richardson’s ongoing business activities, in terms of either the nature of those activities or the timeframe for their occurrence. The Court thus is unable to perceive that the entity’s existence engendered any material change in petitioners’ relationship to the property allegedly transferred thereto. Furthermore, since the only property contributed to HGRCT was 10 units of beneficial interest in HGAMC, creation of this second tier likewise produced no material changes.Page: Previous 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 Next
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