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1985, even though they maintained several bank accounts. Funds
deposited in these accounts during this period came largely from
Mark's earnings and some relatively small returns on investments.
In 1982, petitioners made over 200 checks out to cash, some for
as much as $4,000. Dozens of the checks were for $100 or more.
Both petitioners wrote like numbers of checks to cash in each of
the other tax years in question using three different accounts
with Chemical Bank; i.e., a checking account and an unidentified
second account for the entire period, and a money market account
from 1983 to 1985. Marla tended to write her checks to cash for
$100 or less, while Mark wrote checks to cash for much larger
amounts, including several for $5,000. Mark also drew cash from
a First Boston brokerage account and a Dreyfus liquid assets
account. Mark used much of the money to purchase illegal drugs.
Mark regularly transferred funds between his various bank
accounts, which included brokerage accounts, first at Goldman,
Sachs & Co. during the years when he worked there, then at First
Boston. These accounts, along with a Dreyfus liquid assets
account, served as Mark's vehicles for conducting both his
personal spending and his investment activities.
Petitioners paid for three major purchases on credit during
the tax years: their house, the lease of the second Mercedes-Benz
automobile, and another automobile, a Cadillac, bought in 1980.
They missed no payments on any of these three obligations,
although some of the payments made on the Cadillac in 1982 and
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