Yes, but the problem that you have is that all of those reasons...

Yes, but the problem that you have is that all of those reasons are irrational, dodgy or noncommercial.

1. Why crystalise a tax loss of $4,600,000 (twice) by selling 23,000,000 shares twice (thats $9,200,000) when you could easily lift the price exponentially by making more efficient use of the capital. The fact is you don't, its not rational. The taxes on those kinds of numbers doesn't justify the capital losses. Not when you have the ability to make decisions that influence the share price.

2. If he is selling them to associates, the question is WHY? He owns the shares, it won't change the outcome of a takeover bid. His associates would be better suited buying shares on the market slowly and accumulating. Its not rational. Why would you sell shares with an NTA of what, 13 to 14 cents? Its not rational.

3. You suggest that he is transferring them out of his name into shadow associates where he still has control? Why? Do you really believe that a managing director who is engaging in that kind of behavior is a company that should be invested in? Furthermore you have no evidence, what you are actually doing is forcing a scenario based on your desired outcome because you are anchored on this view that your decision to invest was correct and that you will get your money back.

4. They have been talking about partnering with somebody in Australia for years. Its not hard, David Jones, Myer, Target, Kmart, BigW have all been in the market looking for suppliers. If the product is as good as they make out and as popular, Target would be all over it. They have been aggressively looking for product in the menswear space for years.

5. Why would you leave 20 million dollars in a transaction account? If this is a legit business, the balance wouldn't fall below 15 million. If you actually cared about the performance, you would make more efficient use of the capital. Put 10 million of that into a higher interest account, get between 2% and 2.5% and your earning another 200k / 250k pa.

Interestingly the best thing that has happened is that he has reduced his holding to under 50%. This allows for an activist shareholder to step in and push for new directors and execute a new strategy.

Hell, when he puts his next 23,000,000 shares up for sale and we get to see the shareholder register again (6 months from now), it might be worth having a look at just to find out if the $$$ are actually there.

Has anybody actually gone to the AGM and asked the auditors what they did to verify the $$$? Are they just ticking and flicking based on a bank statement or going to the bank and actually checking?

Ultimately based on the managing directors actions, he is either being dodgy or irresponsible with shareholder equity. Neither is a glowing endorsement.