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(Mr. Kiritopoulos). During at least part of that year, Mr. Vulis
had signature authority over a bank account maintained by Mr.
Kiritopoulos (Kiritopoulos’ account). Pursuant to that author-
ity, on the date shown below, Mr. Vulis signed the following
check that was drawn on Mr. Kiritopoulos’ account, payable to
petitioner, and deposited into petitioner’s equity line account:
Date of Description and Amount
Deposit Payor of Item Deposited of Deposit
8/25/93 Check for $41,500 from Mr. Kiritopoulos $41,500
payable to petitioner
Vladimir Syelsky
During 1992, petitioner engaged in certain income-producing
activities with Vladimir Syelsky (Mr. Syelsky), an immigrant to
the United States who was born in the former Soviet Union.
On August 12, 1992, Mr. Syelsky filed a “NOTICE OF COMMENCE-
MENT OF CASE UNDER CHAPTER 7 OF THE BANKRUPTCY CODE, MEETING OF
CREDITORS, AND FIXING OF DATES” with the United States Bankruptcy
Court for the Northern District of California (Bankruptcy Court).
On September 15, 1992, Mr. Syelsky filed a document with the
Bankruptcy Court that was entitled “DECLARATION CONCERNING
DEBTOR’S SCHEDULES” (Mr. Syelsky’s declaration). In that docu-
ment, Mr. Syelsky declared under penalties of perjury that the
debtor’s schedules and summary of schedules that he filed with
that Court were true and correct. Attached to Mr. Syelsky’s
declaration was a “SUMMARY OF SCHEDULES” in which he reported to
the Bankruptcy Court that he had $100 of total assets and
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