- 11 -
interest). On April 12, 1989, NSA told Camaro that NSA would
retain unpaid commissions otherwise due to Camaro to offset that
potential tax liability.
D. Petitioners’ Bank Accounts
Petitioner maintained a checking account at Central Bank in
Huntsville in 1987 and 1988 for himself (the personal checking
account). TCM maintained an operating account, a money market
account, and a payroll account at Central Bank in 1987 and 1988.
TCM deposited the following amounts to those accounts in 1987 and
1988:
Account
Year Operating Money market Payroll
1987 $1,483,102 $569,428 $688,300
1988 2,153,995 984,528 --
E. Payments to TCM Which Were Not Deposited in TCM Accounts
1. 1987
Between February 9 and September 22, 1987, on behalf of TCM,
petitioner endorsed and deposited to the Double D account 17
checks payable to TCM totaling $19,738.95. Midtex Relays, Inc.,
issued a $2,106.63 check to TCM on July 30, 1987. Petitioner
endorsed the check on behalf of TCM but did not deposit it in any
account maintained by petitioner or TCM. NSA issued a $1,698.35
check to TCM, which petitioner deposited in his personal checking
account on August 27, 1987.
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