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He also deposited 30 bank checks with Howard, Weil, Labouisse,
Friedrichs, Inc., another investment company, during 1987 and
1988. In 1988 petitioner also deposited two First Federal bank
checks with Trans American, and one bank check with New York Life
Insurance Company. The proceeds from the bank checks were used
by the investment companies to buy tax free bonds and stocks.
Petitioner's Cashing of Checks at Circle Food Store
Betty Hebert was employed by Circle Food Store in 1987 and
1988. In 1988, she was the financial manager.
During 1987 and 1988, as well as other years, Circle Food
Store offered a check cashing service. It would charge a fee to
cash a check. The fee would range from 75 cents to $3.50,
depending upon the amount of the check being cashed. Once Circle
Food Store cashed the person's check, it would deposit that check
into its own bank account.
During 1987 petitioner cashed 135 income checks at Circle
Food Store which were written by attorneys or other third
parties. The total amount of these checks was $85,493. During
1988 petitioner cashed 63 third party checks at Circle Food
Store. The total amount of these checks was $30,629.50.
During 1987 and 1988, as well as other years, Circle Food
Store had an arrangement with attorney Louis Gerdes by which his
checks could be cashed at Circle Food Store. During 1987 and
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