Eric Wynn - Page 10

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          1984, Mr. Grillo drew another check on Walter Capital's checking            
          account to Joe Bass, also at petitioner's request.  This check,             
          for $30,000, was deposited in the Joe Bass account at the Trust             
          Co.  Mr. Grillo never met anyone named Joe Bass, and no one named           
          Joe Bass ever worked for Walter Capital.  The Walter Capital                
          checks to Joe Bass were not for services rendered directly by               
          anyone named Joe Bass.                                                      
                                       OPINION                                        
               Respondent alleges that petitioner embezzled funds from                
          Renaissance by drawing Renaissance checks (and causing F&M to               
          issue a check) to a bank account in the name of Ron Gelfman and             
          failed to report these funds as income on his 1983 Federal income           
          tax returns.  Respondent also alleges that petitioner embezzled             
          Renaissance funds by drawing Renaissance checks to W&Y and to F&M           
          in payment for personal jewelry.  Finally, respondent claims that           
          petitioner failed to include fee income that Walter Capital paid            
          to Joe Bass.  The following schedule lists the amounts still in             
          issue:                                                                      
                                          1983                     1984               
          Renaissance to Ron Gelfman              $68,200        ---                  
          "         " "       "                   45,000         ---                  
          F&M to Ron Gelfman                      10,755           ---                
          Renaissance to F&M                      18,077         $6,750               
          Renaissance to W&Y                 1,650          7,050                     
          Walter Capital payments to Joe Bass     ---            30,000               
          "         "    "      "   "  "          ---          25,000                 
          Total:                             143,682        68,800                    







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