Michael W. Rehtorik, et al. - Page 6

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          resell to investors in the normal course of GSC’s retail                    
          securities business.                                                        
               Some managed account funds, along with other funds such as             
          petitioners’ substantial salary income, were deposited into bank            
          accounts in petitioner’s name, from which accounts funds were               
          used by petitioner for business expenses and investments relating           
          to GSC and also for personal purposes.                                      
               The following schedule reflects, for the years in issue,               
          managed account funds that were deposited into GSC’s corporate              
          bank accounts, our estimate (based on the evidence before us) of            
          managed account funds that were deposited into bank accounts in             
          petitioner’s name, and total deposits into bank accounts in                 
          petitioner’s name.                                                          

                  Managed Account Funds Deposited Into        Total Deposits          
                      GSC’s          Bank Accounts       Into Bank Accounts           
            Year     Bank AccountsIn Petitioner’s Name  In Petitioner’s Name          
            1984       $271,13O             $177,778$299,965                          
            1985        226,255 158,340             312,039                           
            1987          7,000        200,000               293,212                  
            Total   $504,385    $536,118            $905,216                          

               At the end of 1986, petitioner hired a new accounting firm             
          to perform for 1986 a yearend audit of GSC’s books and records.             
          This accounting firm determined that GSC’s books and records were           
          not complete.  In 1987, upon verifying through yet another                  
          accounting firm serious errors and omissions in GSC’s books and             
          records and on advice of GSC’s corporate counsel, petitioner                





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