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checking account at Chemical Bank in the name of Real Services.
At the request of Chemical Bank, her lawyer obtained an employer
identification number (EIN) for Real Services.
Petitioner gave the name “Real Services” for use on the
sales slips she received when she purchased electronic equipment
for resale. Instead of giving an identifying number for Real
Services, however, petitioner used her own Social Security number
when requesting exemptions from State sales tax for these
purchases.
Petitioner made deposits into the Real Services’ checking
account totaling $46,242.81 in 1989 and $73,351.08 in 1990. In
October 1989, petitioner wrote a check on this account for $500
to her brother and another for $250 to her sister as birthday
presents. The next month petitioner wrote a check on this
account for $900 to pay private school tuition for the daughter
of her companion, Laura C., and another check to pay for Ms. C.’s
contact lenses. In 1990, petitioner paid $100 for an exercise
class with a check drawn on the same account. The account was
closed in December 1990.
Petitioner also maintained two accounts at Chemical Bank in
her own name. She deposited $2,500.00 and $2,452.61 into one
such account in 1989 and 1990, respectively. Into the other
personal account, she deposited $12,711.48 in 1989 and $12,373.85
in 1990.
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