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from other sources into account 01150, a personal bank account
maintained by Mr. Makalintal in his and petitioner’s names.
Generally, the funds transferred into account 01150 were then
withdrawn and transferred into account 01206, another personal
account maintained by Mr. Makalintal in his and petitioner’s
names or into various bank accounts of the California
corporations owned and operated by Mr. Makalintal.
In 1986, 1987, and 1988, petitioner made occasional
withdrawals from account 01206 but only at the specific direction
of Mr. Makalintal. Petitioner also wrote checks on account 01206
but only to payees and in amounts that were approved by
Mr. Makalintal. In 1987, on account 01206, petitioner wrote 314
checks totaling $146,282, and in 1988, petitioner wrote 665
checks totaling $367,323.
At the specific direction of Mr. Makalintal, petitioner
occasionally transferred funds among the various personal bank
accounts that Mr. Makalintal maintained and the separate bank
accounts of the various California corporations. Mr. Makalintal
did not disclose to petitioner the source of the funds that she
was directed to deposit into the various bank accounts nor the
reason for the withdrawals and deposits that she was directed to
make among the various accounts.
Other than data entry, the transfer of funds among the bank
accounts, and the writing of checks, as described above, all done
at the specific direction of Mr. Makalintal, petitioner was not
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