Srichai and Pusadee Rungrangsi - Page 9

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          order to place the restaurant's assets outside the reach of                 
          creditors.  He asserted that he neither owned nor operated the              
          restaurant after September 15, 1993, and that he thereafter                 
          considered Ms. Eagatatt to be the owner of the restaurant.                  
               Based on the entire record, we conclude that no sale took              
          place.  Mr. Rungrangsi admitted that the restaurant's business              
          license remained in petitioners' names after September 15, 1993.            
          Indeed, the record is unclear when and if the license was ever              
          changed.  The business checking account at Sanwa bank was never             
          changed to make Ms. Eagatatt a signatory thereon, or to remove              
          petitioners as signatories.    More  importantly,  petitioners              
          continued to utilize the Sanwa business checking account after              
          September 15, 1993, in the same manner as they had previously used          
          the account--drafting checks out of the account and endorsing and           
          depositing checks into the account.                                         
               During 1994, petitioners made deposits totaling $107,945.98            
          into the Sanwa business checking account and wrote checks totaling          
          $52,238.21 for apparent business expenses out of the Sanwa business         
          checking account. Further, during 1994 petitioners wrote checks to          
          themselves or for personal expenses out of the Sanwa business               
          checking account.                                                           
               Even though the bulk sale notice indicated that Ms. Eagatatt           
          would be responsible for all of Stanton Mexicatessen's liabilities,         
          during 1994 petitioners continued to write checks to First                  

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