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3. Speck
Petitioner did not explain, nor did she provide any
documents illuminating her relationship with Speck. Although
petitioner testified that she did not control all the assets held
in the name of Speck during 1999 and 2000, she offered no
evidence or documentation that anyone other than herself was the
grantor of, was a beneficiary of, or controlled Speck.
On August 10, 1998, Speck issued to Krismon Buttes, LLC
(Krismon Buttes), an entity in the business of real estate
investment, invoice No. 303 for “International Marketing services
rendered for the years 1998 thru 2000” in the amount of $70,000.
Krismon Buttes issued check No. 1023 to Speck on August 19, 1998,
in the amount of $70,000. William A. McGlothlin
(Mr. McGlothlin), bookkeeper for Krismon Buttes from 1996-2002,
testified that he issued to Speck a Form 1099 after check No.
1023 was issued. Check No. 1023 did not clear Krismon Buttes’s
checking account. Mr. McGlothlin was instructed to void check
No. 1023.
More than a year later, on September 28, 1999, Krismon
Buttes issued check No. 1027 in the amount of $70,000 to Property
Resources as a replacement for the original check No. 1023.
Check No. 1027 cleared Krismon Buttes’s checking account and was
deposited into a payee account at Swiss American Bank Limited,
High Street, St. John’s, Antigua. Respondent attributed the
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