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Deemer, and Ricky and Ana Flores. Petitioner claimed deductions
on his Schedules E, Supplemental Income and Loss, for many of
these real properties.
G. Petitioner’s Bank Deposits
During 1990, 1991, and 1992, petitioner deposited
significant sums of money into seven noncorporate bank accounts
over which he had signatory authority.15 The bank accounts were
maintained in the following names: (1) Bank of Milpitas, account
No. 512-001-200593 “George A. Maciel;” (2) Bank of Milpitas,
account No. 512-001-300466 “George A. Maciel c/o Newark Truck &
Body;” (3) Bank of Milpitas, account No. 512-001-303171 “GM
Investments;” (4) Bank of Milpitas, account No. 512-001-102605
“Alviso Rock/HK Racing;” (5) Wells Fargo Bank, account No. 0108-
363904 “George Maciel” and “Peter Viviano;” (6) Wells Fargo Bank,
account No. 0500-325774 “George A. Maciel;” and (7) Wells Fargo
Bank, account No. 6500-059183 “George Maciel.” Generally, these
deposits fall into one of four categories. The first category is
checks made payable to either Alviso or GMT, yet endorsed and
deposited into noncorporate bank accounts over which petitioner
had signatory authority. An example is check No. 35286, made
payable to Alviso for $7,500, the payor of which is Sutter
Insurance Co. and check No. 426 for $13,000 made payable to GMT,
15The record reflects deposits of more than $1.8 million for
the 3-year period; that is, $715,484.75, $412,514.76, and
$757,186.94, for 1990, 1991, and 1992, respectively.
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