- 20 -
those amounts into the Sam Han account. Petitioner owned and
controlled the Sam Han account; Sam Han had no ownership interest
in it. Sometime in 1988 before March 8, petitioner placed
$70,000 of IL NA Tours’ funds into Albank No. 3, one of his
personal accounts. On March 8, 1988, petitioner withdrew $70,000
from Albank No. 3 and placed it into the Sam Han account. On
March 9, 1988, petitioner withdrew $80,000 from a bank account
maintained by SF NA Tours and placed it into the Sam Han account.
The $80,000 had been transferred in 1987 to the SF NA Tours
account from IL NA Tours’ funds. Thus, between late January and
early March 1988, cash from IL NA Tours’ accounts totaling
$450,000 was transferred into the Sam Han account.13
Other Transfers From Corporate Accounts to Personal Use in 1988
From January 1 through April 3, 1988, petitioner withdrew
$28,000 in cash from IL NA Tours’ Albank No. 1 account for his
personal use.
On January 29, 1988, petitioner took $9,662 from account No.
1-26373 (Albank No. 2), maintained at Albank in the name of IL NA
Tours, and placed it into the Allied account (a personal
brokerage account of petitioner’s).
13 During 1988, in addition to the Sam Han account,
petitioner maintained four other brokerage accounts in Sam Han’s
name into which petitioner placed corporate funds. The record
does not provide information as to the disposition of the assets
in those accounts, and they are not in issue in the instant case.
Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 NextLast modified: May 25, 2011