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G. Bodor had signatory authority over Piccolo’s account with
Second National Bank.17 During the years in issue, G. Bodor
signed the following checks, all of which were drawn on Piccolo
Co.’s Second National 006 account:
Year Amount Payee
1988 $10,000 Purfle Co.
1988 14,000 Purfle Co.
1988 10,000 Purfle Co.
1988 7,630 Purfle Co.
1989 22,571 Purfle Co.
1989 5,000 Purfle Co.
1989 9,597 Purfle Co.
1990 5,000 Purfle Co.
1991 4,400 Purfle Co.
1991 4,479 Purfle Co.
1992 12,000 Purfle Co.
Total 94,677
1This check was issued in 1992 and signed by B. L. Holtzhauer with what
appears to be a signature stamp.
The first seven checks listed above, totaling $78,798, were
deposited into a Dollar Savings and Trust Co. account, account
No. 218-000-827 (Dollar Savings 827 account). The Dollar Savings
827 account was held in the name of Purfle Co. with Eton Trust
16(...continued)
years 1988-1992.
17We note that petitioner’s attorney Frank R. Bodor was the
taxpayer, along with his wife Gina Bodor, in Bodor v.
Commissioner, T.C. Memo. 1993-456, affd. without published
opinion 52 F.3d 324 (6th Cir. 1995). In that case, this Court
found that Robert Temple signed checks for an entity created and
operated by Mr. and Mrs. Bodor pursuant to a plan to create
tiered structures of domestic and foreign trust shell entities to
disguise the fact that Mr. and Mrs. Bodor or their minor children
still owned property.
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