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to transport freight. Mr. Petty also grew distrustful of
H&B's manager, who he felt was closely associated with the
previous owner. Because of this, Mr. Petty asked
petitioner to oversee the disbursement of H&B's funds.
Petitioner agreed, and in April 1988 he began to perform
administrative and supervisory services for H&B, including
writing and signing checks drawn on H&B's bank accounts.
Petitioner never formally received a salary or other
compensation for the services he provided to H&B.
H&B's primary checking account was with the First
Interstate Bank of Oklahoma (First Interstate). Both
petitioner and Mr. Petty were authorized to sign checks
drawn on this account. There was a second checking account
in H&B's name at Community Bank. Petitioner was the only
person authorized to withdraw funds from this account.
Petitioner Judy Montgomery was an officer of Community Bank
during the years in issue.
Petitioner's former sister-in-law, Ms. Ann MacKall,
also performed services for H&B during the years in issue.
Ms. MacKall worked in H&B's office performing basic
bookkeeping and administrative functions. Ms. MacKall
never formally received a salary or other compensation
for her services to H&B.
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