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Lynch Pierce Fenner & Smith, Inc. (Merrill Lynch5) (Merrill Lynch
No. 1), which was opened in the name of Air America and under Air
America’s taxpayer identification number (TIN) but considered to
be IL NA Tours’ account; (2) account No. 879 07787 at Merrill
Lynch (Merrill Lynch No. 2), which was opened in the name of NY
NA Tours and under NY NA Tours’ TIN but considered to be IL NA
Tours’ account; and (3) account No. A19 52547 at E.F. Hutton &
Co., Inc. (Merrill Lynch No. 3), which was opened in the name of
IL NA Tours and under Air America’s TIN and considered to be IL
NA Tours’ account. Hereinafter, we refer to those three accounts
collectively as the corporate accounts.
Transfers Out Of Corporate Accounts in 19876
In June 1987 petitioner opened a brokerage account, account
No. 78-36391001 (Allied account), at Allied Capital Group under
his name and Social Security number, but with the designation
“d/b/a Tours of Illinois”. Notwithstanding this designation, the
5 The brokerage firm’s name changed during the periods
relevant to the instant case, and, at some time, it acquired the
brokerage firm E.F. Hutton & Co. For simplicity, hereinafter we
use the term “Merrill Lynch” to refer to the brokerage firm
Merrill Lynch Pierce Fenner & Smith regardless of the name it
used on a specific date.
6 The transfers of cash and assets from corporate accounts
to petitioner’s personal accounts or accounts under his personal
control that are discussed in this section are not included in
the amounts that respondent alleges are includible in
petitioner’s income in 1988.
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