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accounts was transferred into the Sam Han account in 1988, that
$80,000 was transferred to a custodial account, and that $137,128
in assets remained in the Sam Han account after it was discovered
and made subject to the TRO in late 1988, leaving $232,872 in
cash that petitioner took from his corporations unaccounted for.
Respondent has also shown petitioner’s habit of spending
corporate funds for personal items; for example, respondent has
shown that in 1987 petitioner caused corporate funds of $52,000
to be paid to gambling casinos, $16,000 to be paid on the
mortgage loan on his personal residence, and $51,068 to be paid
into accounts in the names of women who were not employees of
petitioner’s corporations,48 and in 1988 that petitioner diverted
to personal purposes additional corporate funds of $85,688 (that
are not included in the unreported income pled by respondent in
his answer).
Consequently, we find that respondent has shown that
petitioner dissipated for personal purposes or otherwise
exercised dominion and control over the $232,872 in cash
transferred to the Sam Han account that is not otherwise
accounted for. Accordingly, we conclude that petitioner has
48 In this regard, it is also significant that the
diversions we note for 1987 occurred before the stock market
crash; that is, they occurred before the exigencies of the losses
from the stock market crash and Northwest’s ticket recall program
that petitioner contends caused him to divert corporate assets in
order to “hide” them from Northwest.
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