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Petitioner again transferred the Kodak stock on March 17,
1988 (1 day before signing a personal guaranty of his
corporations’ outstanding debts to Northwest, see infra p. 23),
from his personal P-B No. 1 account to account No. 03T 110949 at
Prudential-Bache, which he had opened in January 1988 under the
name and Social Security number of his brother, Sam Han10 (Sam
Han account). Subsequently, on June 20, 1988, 3 days after
learning that Northwest would file suit against him, see infra
pp. 26-27, petitioner transferred the Kodak stock back to P-B No.
1. Petitioner sold the Kodak stock on June 21, 1988, for
$445,596. On June 24, this amount was transferred to a client
trust account pursuant to the terms of a temporary restraining
order obtained by Northwest against petitioner the previous day.
See infra pp. 28-31.
On his 1988 return, petitioner claimed a loss of $3,280
relating to the sale of the Kodak stock; IL NA Tours did not
claim such a loss on its own return. Dividends totaling $4,500
were declared on the Kodak stock while it was held in
petitioner’s FCIS account. As previously noted, those dividends
were deposited into the FCIS account on April 4, 1988. On the
same day, petitioner returned $4,500 to IL NA Tours’ Albank No. 1
10 Sam Han, also known as Seung Soo Han, was not an employee
of any of petitioner’s corporations during 1988.
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