Ronald B. and Annette C. Talmage - Page 35




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          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.                                                                






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