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tax returns but failed to provide any documentation
substantiating the farm expenses deducted in 2001 and 2002.
At a March 17, 2004, meeting between petitioners and Agents
Rans and Beach, petitioner reiterated that his employer owned
most of the Rivercliff property and that he merely owned the barn
and the original dwelling where he resided with his wife, Annette
C. Talmage. Petitioner also stated that he was earning an equity
interest in the property through the services he provided on the
property and the exact respective percentages of ownership would
be determined at a future date.
Additionally, during the meeting, petitioner indicated that
his employer’s name was Mr. Chen14 and the champion dogs living on
the property belonged to his employer. Although the agents
requested, petitioner refused to provide his employer’s contact
information. Petitioner again asserted that pursuant to
nondisclosure agreements with NCPL he was not allowed to provide
any information about NCPL, TPPL, or his employer.
Shortly after the March 17, 2004, meeting, respondent
obtained SSI’s bank statements. After reviewing both SSI’s and
petitioner’s bank statements, respondent discovered that NCPL and
TPPL wire transferred substantial funds to both SSI and
petitioner from bank accounts in Hong Kong. The Hong Kong banks
14 At trial, petitioner testified that Mr. Chen and Mr. Seki
were the same person. However, Mr. Chen/Seki had been deceased
since Oct. 6, 2001.
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Last modified: March 27, 2008