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Camaro’s beneficial owners.4
Camaro had no employees, salesmen, traders, or marketers.
Camaro had no office or employees in Alabama.
a. Petitioner’s Signature Authority Over Camaro Funds
On August 4, 1983, Choy and petitioner opened a U.S. dollar-
denominated savings account and a Hong Kong dollar-denominated
checking account in Camaro’s name at Standard Chartered Bank
(SCB) in Hong Kong. Only Choy and petitioner had signature
authority over those accounts. The accounts were closed on May
1, 1989.
In 1986, at petitioner’s suggestion to Choy, Thomson
McKinnon Securities, Inc. (TM), opened a brokerage account for
Camaro. Only petitioner had signature authority over that
account. On September 30, 1987, TM issued a $23,250 check to
Camaro from funds in Camaro's TM account. Petitioner endorsed
the check as Camaro’s agent to Valar Resources, Ltd., a Canadian
company. Camaro's TM account was closed on February 22, 1988.
b. Petitioner’s Diversion of $12,328 of TCM
Commissions to Camaro in 1983-84
NSA sold electronic components to SCI Components, Inc.
(SCI), of Huntsville in 1983 and 1984. From August 23 to
November 21, 1983, NSA sent seven invoices to SCI for sales of
electronic components. On March 30, 1984, NSA issued a $12,328
4 Kay Chou’s brother-in-law Chen was Camaro’s other
beneficial owner in 1987 and 1988.
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