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During 1988, petitioner handled the banking and supervised
the clerical staff of Superior. Petitioner or his employees made
all bank deposits of receipts for Superior. Petitioner prepared
the 1988 Federal corporate tax return for Superior. Petitioner
reported $50,000 in income from Superior on his 1988 tax return.
During the years in issue, petitioner maintained the
following bank accounts in the names of the following persons or
entities:
Account Name(s) on Account
AmeriTrust #10045-1693 (AT #1 account)St. Clair IH
AmeriTrust #90344-4278 (AT #9 account)Petitioner and St. Clair IH
AmeriTrust #30345-2842 (AT #3 account)St. Clair IH, c/o petitioner1
First Federal Savings #250208704 Superior, d.b.a. St. Clair IMC
Society National Bank #447-8346 Petitioner2
AmeriTrust #48070-9845 (AT #4 account)Petitioner
Huntington Bank #466-478048-7 Manoj Tandon
Independent Savings Bank #03-0-002248Manoj Tandon3
1 In or about Oct. of 1988, the account holder name on the AT #3 account changed from St.
Clair IH to St. Clair IMC.
2 On July 18, 1985, petitioner added his father as additional depositor to the Society
National Bank account.
3 Petitioner had a power of attorney to make withdrawals out of this account.
Petitioner deposited receipts from his medical practice into
the above listed bank accounts as follows:
Account 1985 1986 1987 1988
AT #1 $4,070.00 --- --- ---
AT #9 2,051.85 $16,864.13 --- ---
AT #3 147,704.48132,635.25$153,407.41$30,496.15
First Federal Savings --- --- 2,319.44 ---
Society National Bank19,270.00 55,040.92 56,403.28 13,390.89
AT #4 --- --- 2,087.00 ---
Huntington Bank --- --- --- 1,048.36
Independent Savings Bank --- --- --- 67,596.16
Total 173,096.33204,540.30 214,217.13112,531.56
On May 9, 1985, petitioner wrote a check to cash in the
amount of $24,000 from the AT #3 account. Petitioner paid
attorney fees for his divorce proceedings from the AT #3 account.
During 1987, petitioner paid his son Manoj's tuition to Ohio
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