5
petitioner would get the two best seats available for any concert
or show that he wanted to attend.
Petitioner expected the advances to be returned, but this
did not happen with regularity. To gain some control over the
payment process, petitioner made the necessary arrangements so
that customers could use a credit card to pay Finnimore for
tickets. Petitioner controlled the credit card receipts and also
set up a bank account in the name of Ticketline (Ticketline
account) to hold those receipts. This arrangement made the money
accessible to petitioner rather than having it go through
Finnimore, who otherwise might have kept a fair amount of it.
Petitioner had sole signatory authority on the Ticketline
account. Credit card receipts were deposited directly to the
Ticketline account, and petitioner made periodic deposits into
that account of any money sent to him by Finnimore. He regularly
advanced moneys from this account to Finnimore for the purchase
of tickets.
During 1988, petitioner had signatory authority over three
other accounts: The Todge Trust account, the Universal Life
Church, Inc. (ULC) account, and an equity line of credit.
Petitioner occasionally advanced moneys from these accounts for
the purchase of tickets by Finnimore.
Finnimore did not execute promissory notes for the funds he
received from petitioner. Petitioner reported no interest income
for 1988 related to the funds advanced to Finnimore.
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