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On February 8, 1988, petitioner took $22,000 from account
No. 4-35325 (Albank No. 3) maintained at Albank in his own name,
and put it into his Allied account. On February 16, 1988,
petitioner transferred $22,000 from IL NA Tours’ Albank No. 1
account to his Albank No. 3 account to cover an overdraft in the
latter caused by the February 8, 1988, transaction.
Also during 1988, petitioner used corporate funds to pay the
following personal expenses, loans, or gifts:
Item Amount
Car insurance premiums $3,945
Car repairs 3,250
Real estate insurance premiums 3,168
Real estate taxes 442
American Express charges 4,964
Life insurance 213
Utilities 506
Beverly A. Seman 1,000
Florist bills 305
Attorney’s fees 8,233
Total 26,026
Petitioner did not include the corporate payments of personal
expenditures in income on his 1988 return.
Thus, in addition to the corporate funds used to purchase
the Pan Am and Kodak stock and the $450,000 in transfers of
corporate funds to the Sam Han account, petitioner transferred
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