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president of Colonial Bank, would authorize the extension
of provisional credit to petitioner in the amount of the
deposit, and the bank would pay the envelope draft.
The tax deficiency at issue in this case is
based upon four checks that petitioner deposited into his
personal account at Colonial Bank in August 1989. Each of
those checks was drawn on Motion, Inc.'s account at Tarrant
Bank and was made payable to the "R.H. Bradshaw Car
Account", petitioner's personal account at Colonial Bank.
Motion, Inc., did not have sufficient funds in its Tarrant
account to pay the checks and, in due course, Tarrant Bank
returned the checks to Colonial Bank unpaid. The following
is a list of the checks that were deposited into
petitioner's account at Colonial Bank, the date each check
was deposited, and the date each check was returned unpaid:
Date
Check No. Amount Deposit Date Returned Unpaid
11401 $235,617 8/10/89 8/24/89
11423 237,488 8/14/89 8/22/89
11425 220,481 8/14/89 8/21/89
11426 192,440 8/15/89 8/22/89
Total 886,026
Based upon petitioner's deposits of the above checks
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