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were deposited into these accounts. Petitioner and his mother
maintained joint safe deposit boxes at Sun Bank from 1986 to 1989
and at California Federal Bank during 1990. Petitioner also
maintained safe deposit boxes in his own name at Huntington Bank
and National City Bank from 1986 to 1990.
Petitioner purchased 10 automobiles during the period
November 1986 to December 1990. At least one of the automobiles,
a 1990 Mazda, was purchased with cashier’s checks showing an
individual other than petitioner as the remitter. That
individual did not consent to the use of her name in the
transaction. Petitioner maintained message, mobile phone, and
cellular phone service under three different assumed names.
Petitioner’s sole income-generating activity was illegal
narcotic sales. However, when interviewed by respondent’s agents
in 1991, petitioner stated that he had no sources of income and
that he was fully supported by his family. Petitioner did not
keep records of his income-generating activities and used cash
frequently. Consequently, respondent determined petitioner’s
income by using the “net worth method”. In making the
determination of petitioner’s opening net worth, respondent
determined the total amount contained in petitioner’s bank
accounts, the amount of other cash on hand, and other known
assets.
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