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The three bank accounts were in the following names:
William Howard P.A. Trust, William Howard P.A., and Heartland
Management. Petitioner was the sole shareholder, officer, and
director of Heartland Management, a corporation which held title
to real property that was used by petitioner as a personal
residence and did not generate any income during 1987 and 1988.
William Howard P.A. was a Florida professional services
corporation, of which petitioner was the sole shareholder,
officer and director. Neither petitioner nor William Howard P.A.
nor Heartland Management filed Federal income tax returns for the
years 1987 and 1988.
During 1987 and 1988, petitioner wrote large checks from
these three accounts for his personal benefit, spending the bulk
of the Putmans' inheritance. Among other things, petitioner used
estate proceeds of approximately $132,000 to pay down the
mortgage loan on his personal residence, approximately $47,000 to
pay his personal tax obligations, and approximately $25,000 to
settle a lawsuit unrelated to Mrs. Putman's estate. Petitioner
also made other expenditures, including the construction of a
boathouse and Jacuzzi, as well as paying himself and his
secretaries salaries from the estate proceeds. All these
expenditures were made without the knowledge and consent of the
Putmans.
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