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and $5,658, respectively, were made into Cullen Bank account
number 50-0188921 (Cullen #921). Cullen #921 was styled “Manila
Exploration Company-Eldridge”.
In 1993 and 1994, deposits totaling $120,800 and $55,663,
respectively, were made into Cullen Bank account number 50-
1211226 (Cullen #226). Cullen #226 was styled “Manila
Exploration Company Rizal”.
For convenience, Cullen #453, Cullen #921, and Cullen #226
are hereinafter collectively referred to as the Manila Accounts.
The Manila Accounts were not client trust accounts. Petitioner’s
Social Security number was the only Social Security number on the
Manila Accounts. Petitioner was one of two signatories on the
Manila Accounts, and each of the Manila Accounts required only
one signature.
The Manila Accounts bank statements were sent to petitioner
at his law office address. Petitioner received the bank
statements for the Manila Accounts for 1992, 1993, and 1994.
Petitioner made intrabank transfers between the Manila
Accounts. Petitioner also made intrabank transfers from the
Manila Accounts to a “trust account” he had at Cullen Bank,
account number 50-0784338 (Cullen trust account). During the
years in issue, petitioner deposited money that was income to him
into his Cullen trust account. During the years in issue,
petitioner wired at least $214,000 from the Manila Accounts to an
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Last modified: May 25, 2011