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Savings Account 3/8/90 1,299.67
(First Interstate Bank)
Certificate of Deposit 8/28/89 10,461.23
(Great American First
Savings)
Certificate of Deposit 9/27/89 21,417.21
(Columbia Federal
Savings & Loan)
Brokerage Account 11/26/89 12,855.39
(Shearson Lehman Hutton)
As of the time of trial, the above accounts had been
dissipated. Mr. Espinosa also did not own real property or a
vehicle and, since his termination from Lidak, has had no source
of income.
Tax Liability of Mr. Espinosa
Mr. Espinosa did not file timely Federal income tax returns
for the years 1980, 1981, 1982, 1983, 1984, or 1985. His last
previous return was filed from either Boston or New Jersey during
his employment with Johnson and Johnson. In late 1987, the
Internal Revenue Service (IRS) began an investigation into the
potential tax liability of Mr. Espinosa. This examination
culminated with statutory notices of deficiency for taxable years
1980 through 1985 being sent to Mr. Espinosa. Respondent’s
certified mail list indicates that the notices were mailed on
April 5, 1989, and were addressed to “2200 Sacramento, Number
604”, “San Francisco, CA 94115-2305”.
At the time the notices were issued, the IRS file on Mr.
Espinosa contained an entry, dated January 19, 1988, which stated
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Last modified: May 25, 2011