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Beginning in December of 1982, Mrs. Miravalle wrote out checks
from the Fortune Federal account to "Cash" and, beginning in
September 1983, to King-Air. The latter checks were deposited
into the King-Air account at Bank of Indian Rocks described
below. Fortune Federal began printing the account holder's
Social Security number on the monthly statements with the January
1984 statement. The account was closed on July 30, 1984, and the
balance transferred to a money market account at Fortune Federal.
During some portion of the years at issue, Mrs. Miravalle
had a checking account (Account No. 14806653249) at Atlantic
National Bank in the name Lillian Joy Miravalle. Deposits into
this account during 1983 included transfers from the Park Bank
account and a check in the amount of $2,960.91 made out to cash
with the notation "King Air-AC". On or about August 23, 1983,
Mrs. Miravalle opened up a money market savings account (Account
No. 54800011355) at Atlantic National Bank in the name Lillian
Joy Miravalle by transferring $30,000 from the Atlantic National
Bank checking account.
Petitioners maintained two accounts (Account Nos. 104-105-
300 and 104-105-312(business checking)) at Bank of Indian Rocks
in the name of King-Air, which were opened on or about July 21,
1983, by Mrs. Miravalle. The authorized signatory was Mrs.
Miravalle using the name J. Smythe; the Social Security number
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