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recall program would disclose any ticket stock that a
consolidator had sold but not yet reported to Northwest, because
a consolidator had to return either its old ticket stock or
payment for that stock by a specified date.
In December 1987, petitioner received notice of the ticket
recall program. He realized the ticket recall program would
require him to account to Northwest for all amounts his
corporations owed for ticket stock Northwest had previously
issued to them. Additionally, petitioner realized that neither
he nor his corporations had sufficient funds to pay Northwest
what his corporations owed it for previously issued ticket stock.
Petitioner feared that Northwest would seize his corporations’
assets as payment toward the debt they owed Northwest.
Transfers Out Of Corporate Accounts Into Petitioner’s Personal
Accounts in 1988
After learning of the ticket recall program, petitioner in
early 1988 transferred approximately $1.3 million from IL NA
Tours corporate funds into a personal brokerage account to
purchase stock held in that account. IL NA Tours maintained a
money market account, account No. 8-20911 (Albank No. 1), at
Albany Park Bank and Trust (Albank9). Between January 7 and
9 Albany Park Bank & Trust operated under various names
throughout the years. For consistency, we will use the name
“Albank” to refer to that financial institution regardless of its
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