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personal checking account, $2,100 in cash into the Walter Killeen
checking account, and currency in the amount of $12,285 into the
Anthony J. Medina, Jr. Co. account. In addition, petitioner made
various expenditures of cash for personal items during 1982, and
purchased with currency 232 personal money orders totaling
$82,477.89 from Oak Trust10.
Of the 232 personal money orders purchased by petitioner
during the year 1982, 65 money orders totaling $29,585.51 were
used to pay expenses of Savage, and another 49 were deposited
into accounts of Savage Management, Inc. With the exception of a
de minimis amount, the funds deposited into the Walter Killeen
Co. account during 1981 and 1982 were used to pay expenses of
Savage. Also, with the exception of a de minimis amount, the
funds deposited in the Northern Trust account in the name of
Anthony J. Medina, Jr. Co. in 1981 and 1982 were used to pay
expenses of Savage.
The Criminal Investigation and Subsequent Proceedings
Sometime in the year 1982, petitioner came under
investigation by the Criminal Investigation Division of the IRS.
10The parties have stipulated as an exhibit a copy of a
document containing pages pertinent to the year 1982. The pages
are separately titled, "Personal Money Orders Purchased With Cash
By Steven Toushin At The Oak Bank and Trust" and "Personal Money
Orders Purchased With Cash By Steven Toushin At The Oak Bank and
Trust [,] Handwriting Examined". Also stipulated are exhibits
consisting of photocopies of money orders and other associated
materials.
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