- 45 - $445,59827 and transferred the proceeds to ANB No. 1, a custodial account governed by the TRO. In January 1991, pursuant to the settlement agreement, Northwest received $541,983 and petitioner and his corporations received $1,925 from ANB No. 5 (which had been funded with money transferred from ANB No. 1 through ANB No. 6). See supra note 26. On April 11, 1988, petitioner transferred the Pan Am stock to another personal brokerage account, P-B No. 2, which contained the proceeds of the Gerber stock (diverted from a corporate account in 1987) as well as other assets of petitioner’s. The Pan Am stock was then sold on April 22 and May 20, 1988, for a net of $104,143.28 On May 26, 1988, petitioner transferred $271,836 in cash from P-B No. 2 to ANB No. 2, a custodial account governed by the TRO. In January 1991, pursuant to the settlement agreement in the Northwest litigation, Northwest received $323,017 and petitioner and his corporations received $3,749 from ANB No. 2. See supra note 26. With respect to the transfers between the corporate Albank No. 1 account and petitioner’s FCIS account, respondent determined that the “net” amount taken from and not returned to 27 Petitioner reported the loss from the sale of the Kodak stock on his individual return; IL NA Tours did not report it. 28 The loss on the sale of the Pan Am stock was not reported by petitioner or by IL NA Tours on their respective returns.Page: Previous 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 Next
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