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Diesel Power 1972-1976 Yes Diesel Power Banque
de Paris
Diesel Power Unknown Unknown Diesel Power Channel
Island
WHIP 1972-1976 Yes WHIP Barclays
Bahamas
WHIP Unknown Unknown WHIP Banque de Paris
All Patents 1972-1976 Yes All Patents Banque
de Paris
IGOS 1974 Yes IGOS CNB Columbus
Interrep, S.A. 1973 Unknown Interrep Banque
de Paris
During 1973 petitioner wrote checks to himself on the Diesel
Power Bank of America account5 in the amounts of $30,000, $75,000,
$90,000, and $10,500. These checks were endorsed for deposit
into either a CTC account or one of petitioner's personal
accounts. An additional $50,000 was withdrawn from this account
during 1973 and paid to petitioner/CTC. The CTC cash receipts
journal reflects each of these amounts received as a loan.
However, there is no other documentary evidence of a loan between
petitioner and Diesel Power at this time, nor is there any
documentary evidence that such a loan, if it existed, was ever
repaid. Petitioner also wrote a check to himself in the amount
5 Although the account number that appears on the checks contained in
Exh. 508-SN is different than the stipulated account number for the Diesel
Power Bank of America account, the parties have stipulated that the checks
contained in that exhibit were written on the same account. Therefore, we
assume that the difference in account numbers is of no significance and that
there was only one Diesel Power Bank of America account.
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