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interest in Trust 768 to petitioner.
During February 1988, Trust 768 purchased for $85,000 61
acres of land situated in Piatt County, Illinois (Illinois land),
on which a gravel and sand pit (gravel pit) was located. To
facilitate that purchase, Trust 768 borrowed $50,000 from Cham-
paign National Bank, and Mr. Morris wrote a check for $20,000 to
Trust 768 drawn on a joint checking account that petitioner and
Mr. Morris maintained at the First State Bank of Monticello
(joint checking account).7
On June 15, 1988, petitioner and Mr. Morris assigned their
beneficial interests in Trust 768 to Meadows. Thereafter, Trust
768 conducted no activities except for maintaining a bank account
at the Champaign National Bank (Trust 768 account) on which Mr.
Morris was the sole signatory and into which he deposited certain
of the embezzled funds.
Meadows
Meadows, which was incorporated on May 2, 1988, was involun-
tarily dissolved on October 1, 1991. During the years at issue,
petitioner was Meadows' sole stockholder, served as its presi-
dent, signed certain corporate documents on its behalf, was a
signatory on a checking account maintained on its behalf at the
National Bank of Monticello in the name of petitioner and Mr.
Morris (Meadows account at the National Bank of Monticello), and
7 The record does not disclose the source of the remaining
$15,000 that Trust 768 used to purchase the Illinois land.
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