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From 1984 through 1987, petitioner also made certain
repayments to investors of principal and payments of interest
with respect to managed account funds, and petitioner used funds
withdrawn from the bank accounts in his name for such repayments
of principal and payments of interest.
Also, in 1987, with funds withdrawn from the bank accounts
in his name, petitioner purchased for and in the name of GSC
$37,725 in gold Krugerrands, which Krugerrands were later sold at
a profit that GSC received.
On February 27, 1987, after having received $100,000 from a
new managed account investor and after depositing such $100,000
into one of the bank accounts in his name, petitioner purchased
with funds withdrawn from the same bank account into which the
$100,000 had been deposited a cashier’s check for $100,000 that
was endorsed over to GSC America. This $100,000 was then
transferred from GSC America to GSC and was apparently used for
GSC’s expenses and investments.
The following schedule reflects and, where necessary,
estimates for each year the amount of GSC’s expenses that were
paid with funds withdrawn from the bank accounts in petitioner’s
name, including funds used to participate in hedge transactions,
funds used to pay principal and interest to managed account
investors, funds used to purchase gold Krugerrands, and the
$100,000 that in February of 1987 petitioner received from a
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