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totaling $60,000 in 1987, $60,000 in 1988, and $60,000 in 1989.
Petitioners deposited all of these checks into the Bridge Street
account.
Petitioners sometimes bought items or paid expenses using
cashier's checks which they purchased with cash or using the
proceeds of cashier’s checks which they purchased with cash and
which were payable to Mr. Bernard.2 In September 1988, they
bought a boat (the Tollycraft) for $196,620. They paid part of
the Tollycraft’s purchase price with the proceeds of three $9,000
cashier's checks which they had purchased with cash on July 25
and 26, 1998, and August 11, 1998, respectively, and which were
payable to Mr. Bernard.3 They paid another $150,025 of the
Tollycraft’s purchase price with the proceeds of a loan. They
reported for State sales tax purchases that the purchase price of
the Tollycraft was $161,021, and they remitted to the State of
Michigan a $6,585.84 cashier’s check (payable to the State of
Michigan) in payment of the sales tax. In 1989, Ms. Barnard paid
her childcare expenses using cashier’s checks in the amounts of
2 Petitioners also bought items and paid expenses using
other than cashier’s checks. Many of these items and expenses
exceeded $10,000 in amount.
3 Each of these cashier’s checks listed on its face that Mr.
Barnard was the purchaser of the check. Mr. Barnard signed these
checks and presented them to the Tollycraft’s seller in partial
payment of the boat.
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