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Savage Management, Inc. (Savage) on September 1, 1982. On
corporation papers filed with the State, the president of E & A
of California and later of Savage was listed as Walter Killeen.
Two hundred shares of stock of E & A of California were issued in
the name of Walter Killeen on August 10, 1982.3 E & A of
California, and subsequently Savage, operated under the name of
"The Screening Room".4
From May 1981 through March of 1982, checking account number
332-232 in the name of Walter Killeen Company was maintained at
Oak Trust & Savings Bank (Oak Trust) in Chicago. Petitioner was,
along with Walter Killeen, a signatory on this account.5
From 1978 through the year 1982 petitioner also maintained his
personal checking account, number 501-344, at Oak Trust.6
Petitioner was a signatory on other Oak Trust checking
accounts held in the names of E & A of Illinois, Toushin &
3On the Savage Form 1120, U.S. Corporation Income Tax
Return, filed May 31, 1983, there are attached schedules
declaring petitioner to be the sole shareholder of the reporting
corporation for fiscal year ending September 30, 1982. See infra
note 11.
4Fictitious Business Name Statements were filed with the San
Francisco County Superior Court first by E & A and then by
Savage.
5Based upon a visual examination of copies of canceled
checks that are exhibits stipulated by the parties, all the
checks written on this account appear to be signed by petitioner.
6The parties have stipulated and attached as exhibits copies
of bank statements, cancelled checks, deposit slips, and
associated miscellaneous items for this account for the years
1978 through 1982.
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