Homer L. Richardson - Page 67

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               evasiveness and deceit concerning the couple’s                         
               finances. [Id.; citation omitted]                                      
               Here, the degree of involvement suggested by the documentary           
          record, in the absence of any credible countervailing testimony             
          by Mrs. Richardson, is fatal to her claim.  Mrs. Richardson was a           
          director of HGAMC and a trustee of HGRCT.  She executed each of             
          the documents involved in establishing and operating the                    
          entities, including the agreements between HGAMC and Asset                  
          Protection Services pertaining to Mr. Richardson’s services.  She           
          signed the minutes for each of the dozens of board meetings,                
          which recounted in notable detail purported activities of the               
          entities.  Perhaps even more importantly, Mr. Richardson                    
          testified at trial that Mrs. Richardson attended all of the                 
          meetings where those matters were discussed.  The Forms 990-PF              
          claim that Mrs. Richardson devoted 2 hours per week to her work             
          as trustee for HGRCT.  Mrs. Richardson also possessed signatory             
          authority over entity bank accounts.  There is no indication of             
          any evasiveness toward Mrs. Richardson on Mr. Richardson’s part;            
          rather, Mrs. Richardson was apparently welcomed as a participant            
          in the HGAMC and HGRCT arrangement.                                         
               Despite the above evidence, petitioners contend on brief               
          that Mrs. Richardson “was undergoing treatment for cancer and was           
          unable to work for the entire 1997 tax year.  She is 69 years               
          old, works as a medical assistant and has a high school                     
          education.”  They also make reference to her being “unschooled in           





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