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During the years at issue, petitioner maintained a checking
account at a local institution on behalf of Fruitland. Both
petitioner and Carlton were listed as owners of the account.
While petitioner made deposits to this checking account as needed
to conduct Fruitland's daily activities, he collected and stored
much of the cash generated by Fruitland's operation in paper
bags. Petitioner transported these bags of cash to and from
Fruitland's place of business each day. Often, while at his
residence, petitioner stored the bags of cash under his bedroom
mattress. When the quantity of cash got too burdensome,
petitioner used the cash to purchase cashier's checks. Each
cashier's check listed petitioner as the sole payee. Petitioner
stored these cashier's checks in two safety deposit boxes
maintained at a local bank. Although Carlton was aware of the
existence, contents, and location of these safety deposit boxes,
he did not have authorized access to them. Only petitioners had
access to the contents of the safety deposit boxes. During the
years at issue, petitioner purchased cashier's checks in the
following amounts and on the following dates:
Taxable Year 1987
Date Amount
June 2, 1987 $5,000
July 9, 1987 5,000
July 9, 1987 5,000
July 17, 1987 5,000
July 17, 1987 5,000
Aug. 25, 1987 5,000
Aug. 25, 1987 5,000
Aug. 25, 1987 5,000
Total 40,000
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