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Because the P-B No. 2 account had been the recipient of the
Gerber stock proceeds, the Pan Am stock proceeds, and other
assets of petitioner’s before petitioner transferred $271,836 in
cash from the account to fund ANB No. 2, the question arises
whether the amount so transferred is traceable to the Gerber
stock, the Pan Am stock, or some other asset of petitioner’s.
Petitioner was actively buying and selling securities
through the P-B No. 2 account in March through May 1988, as well
as making personal charges against the proceeds in the account by
means of a credit card. The Gerber and Pan Am stock proceeds
were commingled with other personal funds of petitioner’s and
were used to offset losses in other stocks in the account that
had been purchased on margin. The statements for P-B No. 2 in
the record do not show a clear source of the funds for the
$271,836 transfer to ANB No. 2. However, because petitioner’s
attorney represented to Northwest that the $271,836 transfer to
ANB No. 2 was the proceeds of the “Gerber account”, we treat this
as an admission by petitioner that the amount transferred was
from that source and no other. Consequently, we find that no
portion of the Pan Am stock proceeds was transferred to ANB No.
2. Instead, the record in this case establishes that the Pan Am
stock was transferred from petitioner’s FCIS account to
petitioner’s P-B No. 2 account on April 11, 1988, sold in two
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