- 33 -
December 31, 1988, the Sam Han account contained assets with a
value of $137,128. The record does not reflect what happened to
the remainder ($232,872) of the $450,000 that petitioner had
transferred to the Sam Han account between January 19 and March
9, 1988.22
Thus, including the so-called Gerber account proceeds
transferred in May 1988 from P.B. No. 223 to ANB No. 2 (in
connection with Belofsky’s proposal for gaining petitioner’s
release from personal liability), by yearend 1988 the following
amounts were on deposit in accounts governed by the terms of the
TRO:
22 The foregoing analysis of the Sam Han account disregards
the transfers of the Kodak stock into and out of that account on
Mar. 17 and June 20, 1988, respectively.
23 By late May 1988, P-B No. 2 contained the proceeds from
the sale of the Gerber stock and from the sale of the Pan Am
stock, as well as other assets. The Gerber stock proceeds are
not included in the amounts that respondent alleges are
includible in petitioner’s income in 1988, although the Pan Am
stock proceeds are.
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