- 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 NextLast modified: March 27, 2008