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He maintained the account during the years at issue in these
cases.
J&J Trucking Deposits
During 1992, petitioner deposited four checks, each in the
amount of $1,399.67, into the trust bank account. Three of the
checks were issued by J&J Trucking Co. (J&J Trucking) drawn on
San Diego Trust & Savings Bank, and one was a cashier’s check
issued by the same bank. The check dated October 29, 1992,
contained the notation “Truck Pymt. Sept-92".
During 1993, petitioner deposited into the trust bank
account 10 checks issued by J&J Trucking totaling $15,396.37.
Nine checks were for $1,399.67 and one was for $2,799.34. The
checks dated August 10 and October 5, 1993, noted the account or
transaction number “9204001".
During 1994, petitioner deposited into the trust bank
account 12 checks issued by J&J Trucking, each in the amount of
$1,399.67. However, one of those checks was returned because of
insufficient funds and was not resubmitted in 1994. Four of the
checks bore notations indicating that the payments were
sequentially numbered.
Miscellaneous Items
On October 28, 1993, petitioner paid $17,300 in cash to
repay in full a loan obligation to Bank of America. The record
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