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Account Amount Source
ANB No. 2 $271,836 “Gerber account” proceeds from P-B
No. 2
ANB No. 1 445,596 Kodak stock proceeds from P-B No. 1
ANB No. 3 80,000 Sam Han account
Sam Han acct. 137,128 TRO amended to cover 10/14/88
Total 1934,560
1 An additional client trust account established by Belofsky
at American National, account No. 14199939 (ANB No. 4), contained
$35,852 transferred thereto on Aug. 15, 1988, from petitioner’s
Allied account pursuant to Hasman’s Aug. 2 authorization.
Although the Allied account contained amounts transferred from
corporate accounts in 1987 and 1988, these transfers are not
included in the amounts that respondent alleges are includible in
petitioner’s income in 1988.
Northwest’s Exercise of Letters of Credit From Petitioner’s
Corporations
On July 26, 1988, Northwest exercised a letter of credit in
the amount of $54,000 from petitioner’s corporations. Northwest
exercised a second letter of credit in the amount of $50,000 from
petitioner’s corporations on August 22, 1988. It exercised a
third letter of credit in the amount of $146,000 from
petitioner’s corporations on August 24, 1988.
The foregoing letters of credit were secured by various
assets of petitioner’s corporations held by Albank as well as
real property owned by petitioner personally.
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