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as shown by their account statements during this time period.5
Petitioners spent substantial amounts of money on airline tickets
and travel, including hotels in Hawaii, San Diego, San Francisco,
and Scottsdale. Petitioners continually shopped at department
stores such as Saks Fifth Avenue, Neiman Marcus, Nordstrom, and
Bloomingdale's. Petitioners' account statements indicate charges
and checks written to numerous restaurants and upscale specialty
stores. In addition, the account statements listed frequent
expenses at the Tucson Country Club.
As petitioners were spending these substantial amounts
against the equity in their stock, they never once made any type
of payment to Drachman. In addition, we note that the value of
the Price Co. stock per share increased following the stock
market crash in October 1987, when petitioners' margin calls
began. In October 1987, the Price Co. stock was valued at $31
per share. In October 1988 and November 1989, the Price Co.
stock had increased to $40.5 and $48.25 per share, respectively.
The stock was supposedly lent to petitioners merely to cover
5 For example, petitioners' account statements for the
following 5-month period indicate that Mrs. Vinikoor wrote checks
to herself for the following amounts:
Date Amount
Mar. 1990 $12,250
Apr. 1990 7,600
May 1990 6,500
June 1990 7,800
July 1990 15,000
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