Replies to post #19239 on Dalrada Financial Corp (DFCO)

[XenaLives]

This is how BONAR pads the income:

The sleight of hand is obvious.. None of DFCO's "divisions" is a viable business...

Dalrada expanded operations throughout fiscal 2021. During the years ended June 30, 2021, and 2020, Dalrada recognized $670,272 and $768,361 in operating expenses, respectively, of penalties and interest within interest expense on the consolidated statements of operations. For years ended June 30, 2021, and 2020, the Company recognized $9,504,041 and $1,229,199, respectively, within “Gain on expiration of accrued payroll taxes” as a result of quarterly tax liabilities that expired during the fiscal years. Dalrada’s net income for the year ended June 30, 2021, was $1,221 compared to a net loss of $2,477,557 during the year ended June 30, 2020.

https://dalrada.com/dalrada-corporation-reports-increase-of-189-in-revenues-and-a-net-operating-profit-in-audited-fiscal-2021-financials/

It's complicated and this document gives the gist of it. It is why all of BONAR's shells were dormant for 10 years and then revived at about the same time when the IRS 10 year statute of limitations expired.

MOTION AND RESPONSE
In his Motion, Defendant seeks to compel Mr. Black and Ms. Fuchs to answer certain deposition questions about an IRS levy in 2013 to various alter egos and/or successors in interest of Allegiant (collectively, "third parties"). [DE 42]. While Defendant believes that questions about this issue are improper pursuant to 26 U.S.C. § 6103(a), Plaintiff believes that he is entitled to the information pursuant to Section 6103(e)(1)(D)(iii) because he is a bona fide shareholder owning one percent or more of the outstanding stock of Allegiant and/or pursuant to Section 6103(h)(4)(A-C), which permits disclosure of tax returns and return information in judicial and administrative tax proceedings under certain circumstances. Id.

These include Smart-Tek Solutions Corp.; Smart-Tek Automated Services, Inc.; Solvis; Medical Staffing, Inc.; Smart-Tek Services Solutions Corp.; American Marine, LLC d/b/a AMS Outsourcing; Allegiant Management Services Corp.; Allegiant Professional Business Services, Inc.; Delrada Financial Corp., Delrada Management Consulting Corp.; Soltex Corp.; Solvis Corp.; Solvis Group; Solvis Medical, Inc.; Solvis Healthcare, Inc.; Call Center HR; Quicktix, Inc.; Heritage Staffing, Inc.; Solvis Nursing Michigan, Inc.; All Staffing, Inc.; Staffing Partners California, Inc.; Employment Systems, Inc.; and Trucept Corp. See DE 42 at pp. 3-4.

In response, Defendant first argues that the motion is time-barred because it was filed more than thirty days after the depositions occurred in violation of Local Rule 26.1. [DE 45]. Defendant next contends that returns and return information are confidential under Section 6103 of the Internal Revenue Code. Id. Defendant explains that, absent an express authorization, Section 6103 bars the disclosure of information regarding parties who are not parties to this proceeding. Id. Defendant explains that the Court must employ the party test, the item test, and the transaction relationship test in order to determine whether the information sought falls under an exception to the privilege, and Defendant argues that Plaintiff fails all three tests. Id. Defendant also argues that Plaintiff could have sought the same information through third-party subpoenas or through questions at Brian Bonar and Colin Niven Bonar's depositions and failed to do so. Id. Finally, Defendant asserts that Plaintiff's requests that the witnesses review their files, bring IRS records to their depositions and travel from San Diego to South Florida for their depositions are improper. Id.

https://casetext.com/case/goldberg-v-united-states-26