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be completed by Mr. Gherman or an FIP employee and then signed by
Mr. Gherman. Between January 1983 and December 1986, Ms. Walters
signed over 11,000 checks, of which she had written only two.
During the years in issue, Ms. Walters also had signatory
authority over two bank accounts that were in her name. Ms.
Walters shared with Mr. Gherman signatory authority on an account
titled "Joan Gherman No. 2 account". Ms. Walters signed checks
written on the Joan Gherman No. 2 account using the same process
that was used for checks written on the FIP account except that
only one signature was required on the Joan Gherman No. 2
account. During the years of its existence, hundreds of
thousands of dollars flowed through the Joan Gherman No. 2
account. Any money earned by Ms. Walters was deposited into the
Joan Gherman No. 2 account. Checks made payable to Mr. Gherman
drawn on the FIP account were deposited into the Joan Gherman No.
2 account. Ms. Walters regarded the Joan Gherman No. 2 account
as a business account. Business expenditures of FIP as well as
some personal expenditures of petitioners were paid from the Joan
Gherman No. 2 account. The bank statements for the Joan Gherman
No. 2 account were mailed to FIP's business address, and the
statements were reconciled by Mr. Gherman or an FIP employee.
The other account in Ms. Walters' name served as her
personal checking account (Joan Gherman No. 1 account). Ms.
Walters used the Joan Gherman No. 1 account for paying basic
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