- 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.
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