- 83 - or otherwise prevent the collection of taxes. Rowlee v. Commissioner, 80 T.C. at 1123. Respondent’s initial contact came from Japanese tax authorities. When respondent’s agents made direct inquiries to petitioner about the source of the funds advanced and the identity of the owners of NCPL and TPPL, petitioner refused to disclose information based upon the confidentiality agreement he signed with NCPL. The confidentiality agreement provided that petitioner had to keep all company “Information” confidential. However, when the party requesting information and documentation was a governmental authority, the confidentiality agreement did not prohibit petitioner from complying with its requests. It only required petitioner to give NCPL prompt notice and to cooperate with it to obtain a protective order or other reliable assurance that any company information unrelated to petitioner would be kept confidential. Even when respondent provided petitioner the opportunity to verify that he did not have bank accounts or signatory authority over bank accounts in Hong Kong, he refused to sign the consent directives, claiming he so refused under instructions from his employer pursuant to the confidentiality agreement. There is no corroborating documentation from NCPL to that effect.Page: Previous 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 NextLast modified: March 27, 2008