- 23 - 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 Reprographics. 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 thePage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
Last modified: May 25, 2011