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of $400,000 during 1973, which was endorsed for deposit to City
National Bank & Trust Company; this check is not reflected on
CTC's cash receipts journal.
During 1974 petitioner wrote checks to himself on the Diesel
Power Bank of America account in the total amount of $531,633.48.
These checks were endorsed for deposit to either CTC or Zand
personal accounts. All of these deposits are reflected in the
CTC cash receipts journal as either loans or reimbursements with
the exception of one deposit in the amount of $40,000, which is
not reflected at all. There is no other documentary evidence of
a loan in the record.
During 1975 petitioner wrote five checks to himself on the
Diesel Power Bank of America account. One check in the amount of
$150,000 was endorsed for deposit to CTC but is not reflected in
the CTC cash receipts journal. A second check in the amount of
$375,000 was endorsed for deposit to a Zand account; it is
reflected on the 1975 CTC receipts journal as a loan. However,
there is no other documentary evidence in the record of such a
loan. Petitioner wrote three additional checks on the Diesel
Power Bank of America account during 1975 in the total amount of
$76,652.03. Two of these checks were endorsed for deposit to
CTC. The third check in the amount of $50,000 was endorsed to
"I.D.S." to purchase stock. The first two checks were listed on
CTC's 1975 cash receipts journal as reimbursements. The check
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