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Ridgewood, New Jersey (Citizens Bank). All deposits to the Hill
account were transferred from the R&S checking account with the
exception of loan proceeds in the amount of $40,000 deposited to
the Hill account on November 24, 1982. In 1982, the below-listed
disbursements, which inured to the personal benefit of
petitioner, were made from the Hill account:
Date
Disbursed Amount Payee Purpose
2/3/82 $28,903 FBF Winery Winery partnership with
petitioner's brother in
California
2/28/82 35,000 Mary Fusco Petitioner's purchase of
residence located in City
Island, New York
5/5/82 20,000 Elaine M. Repayment of loan to
Fitzpatrick petitioner's mother
During February and March of 1982, the Hill account had a mailing
address of 313 Columbus Avenue, New York, New York. The monthly
statements for February and March were undeliverable at that
address, and the statements were thereafter picked up by
petitioner's father, who was an employee of Citizens Bank.
On September 16, 1982, petitioner, acting on behalf of the
Bank, was a signatory to a Building Loan Agreement with Long
Wharf. The agreement authorized the release of $3,115,000 in
construction loan proceeds to Long Wharf.
On September 27, 1982, Landing made a $50,000 payment to
Pares Y Nones, S.A., a Panamanian corporation, because petitioner
had enabled the Long Wharf loan closing to take place in spite of
the fact that Long Wharf did not have any coastal zone management
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