- 12 - 1, and it belonged to him personally. Petitioner transferred the Gerber stock to hide it from a margin call. While in Chung No. 1, the Gerber stock was sold on December 24, 1987, for $335,563. Assets purchased with the Gerber stock proceeds were transferred from Chung No. 1 on February 16 and 24, 1988, to another account that petitioner had directed Chung to open at Prudential-Bache, account No. ATY 065408 (Chung No. 38). Assets in Chung No. 3 were transferred to an account in petitioner’s name, account No. ATY 066749 at Prudential-Bache (P- B No. 2) on March 9, 1988. Petitioner was actively buying and selling securities in P-B No. 2 during March through May 1988. The net balance in P-B No. 2 as of March 31, 1988, was $273,855. The net balance as of April 30, 1988, was $305,642. During 1988, petitioner also used funds in P-B No. 2 to pay personal VISA charges totaling $1,535. On May 26, 1988, $271,836, which petitioner’s attorney represented to be the Gerber stock proceeds, was transferred from P-B No. 2 to a client trust account established by petitioner’s attorney in connection with a proposal by petitioner to secure a release from all personal 8 As with the other Chung accounts, although Chung No. 3 was opened under Chung’s name and Social Security number, Chung did not have an ownership interest therein but instead served only as petitioner’s nominee. Petitioner owned Chung No. 3 personally.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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