- 10 - other clients. If these proceeds were to be held for a long time, Burns transferred the funds to an interest bearing account called the Pierpont Fund Money Market at Morgan Guaranty (Pierpont Account). The money market account was held under the identification number of Burns' law firm, the fact of which petitioner was aware. The account held only petitioner's funds and existed only for her benefit and her corporations' benefit. With petitioner's consent, Burns disbursed money from her Pierpont Account and from her client escrow account to various third parties. These disbursements were in partial satisfaction of petitioner's then existing business and personal liabilities. Only petitioner authorized disbursements from these accounts. Burns furnished petitioner with Form 1099 each year for accrued interest from the Pierpont Account. Petitioner earned interest in the amounts of $14,350, $13,637, $1,951, and $6,440 for the taxable years 1987, 1988, 1989, and 1990, respectively. During the years in issue, an account in the name of Ivory Ranch was maintained at Chase Manhattan Bank (Chase). Petitioner signed all of its disbursement checks. Ivory Ranch's net deposits were as follows: $772,137, $780,254, $71,471, and $114,361 for the taxable years 1987, 1988, 1989, and 1990, respectively. The checks petitioner drew upon this account were as follows: $13,900, $11,000, $1,500, and $9,120 for the taxable years, 1987, 1988, 1989, and 1990, respectively.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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