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2. 1988
On January 8, 1988, Montrose Products Co. issued a $3,918.80
check to TCM. Petitioner endorsed the check on behalf of TCM but
did not deposit it in an account maintained by petitioner or TCM.
The check was cashed. In February and March 1988, on behalf of
TCM, petitioner endorsed and deposited in the Double D account
two checks payable to TCM totaling $1,958.60.
F. Camaro Checks Reported by TCM
TCM deposited two checks from Camaro totaling $11,789.54 in
its operating account in October 1987. TCM reported this amount
on its 1987 return. Between January 4 and October 25, 1988, TCM
deposited checks from Camaro totaling $166,416.10 in its
operating and money market accounts. TCM reported this amount on
its 1988 return.
G. Payments From NSA to Camaro in 1987 and 1988
1. 1987
Between September 11 and November 20, 1987, NSA issued five
checks totaling $298,601.27 to “Camaro Trading Co., Ltd.” or
“Camaro Trading Co., Ltd. Attn: Mr. D. Ishler”. TCM received
these checks in Huntsville but did not deposit them in a TCM
account. TCM sent them to Camaro in Hong Kong.
2. 1988
Between January 4 and December 22, 1988, NSA issued 13
checks totaling $1,569,596.15 to “Camaro Trading Co., Ltd.” or
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