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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.
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