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Of the above-listed unexplained deposits, the following
consisted of cash deposits:
Year Amount
1988 $85,500
1989 46,955
1990 39,000
1991 11,400
On November 23, 1988, Akiko used $9,000 in cash to purchase
a cashier's check. On February 1, 1989, Yoshinori paid $55,320
in cash to purchase a Mercedes Benz. On April 19, 1989, Akiko
used $3,000 in cash to purchase a traveler's check.
During March 1983, Yoshinori, Nakamura, Harry Norager, and a
Dr. Morrison became shareholders in Norager, Inc. (Norager). On
April 1, 1983, Norager purchased the Capri Restaurant from Pier
29, Inc. (Pier 29). The purchase price was $600,000, consisting
of $400,000 in cash, which was borrowed from Alameda First Bank,
and a note in the amount of $200,000 given to the former owners
of the Capri Restaurant. The Takaos owned a 25-percent interest
in the capital stock of Norager. Operation of the Capri
Restaurant was Norager's only business activity. Dr. Morrison
withdrew from the venture in 1984, and Henry Norager withdrew in
1986, leaving only Nakamura and Yoshinori with interests in the
venture after 1986.
On December 31, 1987, Nakamura executed a promissory note on
behalf of Norager wherein Norager promised to pay Yoshinori the
sum of $94,000 with interest from that date at the rate of 10
percent per year. The due date of any unpaid principal and
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