- 11 - Ivory Land also maintained an account at Chase. Its net deposits were as follows: $1,343,034, $647,998, $515,319 and $1,805,311 for the taxable years 1987, 1988, 1989, and 1990, respectively. Petitioner drew checks upon this account in the following amounts: $80,875, $59,005, $52,116, and $59,850, respectively. Petitioner maintained an account at Chase in her name during the years in issue. Net deposits into this account were as follows: $138,698, $90,649, $21,419, and $150 for the taxable years 1987, 1988, 1989, and 1990, respectively. At least $20,000 of transfers into petitioner's account is directly traceable to transfers from Ivory Land and Ivory Ranch. Petitioner's account also received transfers of proceeds from petitioner's leases and horse-related activities in the following amounts: $88,092, $31,015, $8,122, and $8,700 for the taxable years 1987, 1988, 1989, and 1990, respectively. Petitioner fully authorized Mr. Freidus to act as her agent during the years in issue. Mr. Freidus, from time to time, requested that petitioner give him blank corporate checks affixed with petitioner's signature. Petitioner regularly acceded to his requests. Petitioner was aware of the expenditures and investments, which included investments in real estate and horses, which Mr. Freidus made on her behalf. Petitioner knew what checks were being written and what they were used for.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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