- 35 -
development of the Rivercliff property and the costs of its
development.
In response, by letter dated January 25, 2004, petitioner
stated he was employed exclusively by NCPL and at times was
temporarily reassigned to work on projects for TPPL and other
companies at the direction of his employer.13 The letter stated
that, depending on the transaction, his employer instructed him
to use the titles of CEO, chairman, and managing partner. The
letter also claimed he did not receive any money from TPPL’s
transactions and did not have an ownership or controlling
interest in NCPL or TPPL. Furthermore, the letter asserted that
petitioner was prohibited by NCPL’s nondisclosure confidentiality
agreement (confidentiality agreement) from providing any
documentation or information to the Internal Revenue Service
(IRS) with respect to NCPL and TPPL and its owners.
The confidentiality agreement signed by petitioner dated
January 10, 1993, states:
1. Associate agrees to treat as confidential all
technical, business, financial and other confidential
or proprietary information of the Company which is
disclosed to Associate, whether in written, oral, fax
(electronic) or other tangible or intangible form,
including without limitation, corporate information,
client information, investor information, financial
transaction documentation, specifications, know-how,
plans, data, other documentation, reports, ideas,
13 At the beginning of respondent’s examination, petitioner
told the agents he was not authorized to use his employer’s
actual name.
Page: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
Last modified: March 27, 2008