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making deposits. All deposits to the Coast account were from
Eastimpex, drawn on an Eastimpex bank account. All deposited
funds remained in the account until it was closed.
On September 14, 1987, a letter was obtained from petitioner
husband's office at Eastimpex and delivered to Coast by an
Eastimpex employee, directing the Coast account be closed and the
balance, totaling $322,200.01, be issued in checks as follows:
Name Amount
Priscilla Tay (sister of petitioner wife) $86,651.00
Stanley Lee (Shin's general manager until 1986) 32,093.00
Edward Chiu (Shin's general manager from 1986) 48,548.47
Shin I Food Factory Co. 154,907.54
Edward and Ken Chen signed the letter authorizing the closure.
The four checks were given to petitioner husband. The check
issued to Stanley was deposited into his personal account, and
the check issued to Edward was negotiated overseas. The check
issued to Shin was endorsed by Lily and deposited in the First
Pacific account. The check issued to Priscilla was deposited
into an Eastimpex account and then wired to her personal bank
account in Hong Kong.
In 1987, the account was opened at First Pacific in the name
of "Shin I Food Co." with Edward, Ken Chen, Lily, and Priscilla
as signatories. At that time, Eastimpex opened a subsidiary in
Hong Kong, and it was decided that the subsidiary would make the
deposits. First Pacific was chosen by petitioner husband because
it was convenient to the subsidiary. All deposits to the First
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