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petitioner’s records had to be reconstructed because he failed to
maintain proper books and records in the first place.
4. Failure To File Income Tax Returns
Petitioner filed untimely Federal income tax returns for the
years at issue, all of which substantially underreported income.
5. Implausible or Inconsistent Explanations of
Behavior
a. Rivercliff Property Ownership and Advanced
Funds
The record shows that the Talmages purchased the Rivercliff
property on November 17, 1997, and it was titled in both their
names until Kumiko Talmage conveyed her 50-percent interest to
petitioner as part of the divorce settlement on August 20, 2001.
Throughout this period, petitioner represented to Kumiko Talmage,
Multnomah County, the Multnomah County Circuit Court, Mr.
Schommer, Mr. Larson (petitioner’s divorce attorney), Diane E.
Rulien (Kumiko Talmage’s divorce attorney), Mr. Seymour (NCPL’s
attorney) and Steven L. Pfeiffer (petitioner’s property law
attorney) that the Talmages owned the Rivercliff property jointly.
The record also shows that after Kumiko Talmage conveyed her 50-
percent interest to him, petitioner was the sole owner of the
property until he transferred it to RFI on June 30, 2005.
Petitioner also occupied the property as his primary residence
from June 9, 1999, through the date of trial.
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Last modified: March 27, 2008