Henry Deletis, Jr. - Page 5

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          dealership ultimately claimed and was allowed an embezzlement               
          loss on its corporate income tax returns for 1966 and 1967.                 
          Petitioner's Story                                                          
               Petitioner stated that this scheme started in 1965.                    
          Petitioner admitted that it was his idea to "move a few cars",              
          supposedly in order to help Caplan keep the dealership, but that            
          the plan expanded to include many cars.  Petitioner admits that             
          "maybe I got a little greedy, and I took approximately $40,000              
          from that money".  The dealership, according to petitioner, was             
          experiencing financial difficulties resulting from the low volume           
          of sales and the costs of purchasing a new location and building            
          a showroom, after the previous landlord had refused to renew the            
          lease.  Petitioner said the downpayments on the new cars were               
          actually monies transferred from the downpayments on used cars              
          sales.  Petitioner testified that it would have been impossible             
          to maintain this scheme of "moving" cars, obtaining financing,              
          transferring deposits, and making payments on the loans without             
          someone in authority sanctioning these actions.  Petitioner                 
          indicated that the dealership was holding checks for sales that             
          they had noted on the books as paid.                                        
               According to petitioner, General Motors Acceptance                     
          Corporation (GMAC), a subsidiary of General Motors, conducted a             
          review of the dealership approximately a year before the ultimate           

          vehicle, a prerequisite to the purchaser's legally reselling the            

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