- 38 - 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.Page: Previous 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 NextLast modified: March 27, 2008