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job if the bank learned that he was taking money from a trust
client.
Mrs. Millyard kept a checking account at Bank of America.
When a trust client sought to remove money from a trust account,
the client would be asked to complete a "Request for Transfer"
form. Petitioner authorized numerous transfers from the trust to
Mrs. Millyard's checking account. Mrs. Millyard wrote many
checks for the benefit of petitioners, which were deposited into
their accounts.
Petitioner knew that checks in excess of $10,000 would have
been noticed and investigated by Bank of America. Petitioner
also knew that if any of the checks were made out directly to
him, he would lose his job. Checks in amounts less than $10,000
would not appear on the bank's large item report. All of the
checks written by Mrs. Millyard for the benefit of petitioners
were under $10,000. Mrs. Millyard, on occasion, would write
several checks to petitioners over a short period of time. While
each check was less that $10,000, the total amount transferred to
petitioners over such a period was substantially more than
$10,000. On three occasions, Mrs. Millyard wrote multiple checks
on the same day, the total of which exceeded $10,000; however,
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