Walter Van Eck and Friedgard Van Eck - Page 23

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          failure to offer corroborative testimony that they held funds as            
          nominees is a significant factor in determining that they failed            
          to carry their burden of proof).  We conclude that USB account              
          0894 was Walter's account, maintained in the name of                        
               Walter testified that Reprographics conducted no business in           
          the United States except that it purchased certain second                   
          mortgages.  Checks written on USB account 0894 from November 1985           
          through December 1987 are in evidence.  Some of those checks                
          clearly fail to relate to the purchase of second mortgages.  For            
          example, USB account 0894 check numbers 6902 and 6907, in the               
          amounts of $1,200 and $2,000, respectively, were issued in                  
          December 1985, and drawn to "Northwest Dance Center".  On brief,            
          with no citation to the record, petitioners explain those checks            
          as loans, apparently unsecured, "to help a struggling arts                  
          group".  USB account 0894 check number 6979, in the amount of               
          $1,500, was issued in October 1986, and drawn to "Walter J. Van             
          Eck".  On brief, petitioners claim, with the citation of nothing            
          other than the letters "ln" on the check, that such check                   
          represented a loan to Walter (subsequently repaid).  As to                  
          numerous checks that, on brief, petitioners concede were mortgage           
          payments on properties owned by them, petitioners argue that such           
          checks were payments on the "Universal Finance second mortgage"             
          that Reprographics "was purchasing on contract (see the                     

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