- 83 - 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.Page: Previous 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 Next
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