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the payor of which is Daniel Hernandez. Both of these checks are
made payable to Alviso or GMT yet deposited into Bank of Milpitas
account No. 512-001-300466. The second category represents
workmen’s compensation insurance refund checks made payable to
Alviso or GMT and deposited into noncorporate bank accounts over
which petitioner had signatory authority. For example, on or
about July 31, 1992, Republic Indemnity Co., refunded Alviso
$57,472, which petitioner deposited into Bank of Milpitas account
No. 512-001-300466. The third category is payments made to
petitioner from his related entities. An example of such a
payment is check No. 4153 for $2,476.06 made payable to
petitioner from GMT. Lastly, there are substantial sums of cash
and their equivalent deposited into noncorporate bank accounts
over which petitioner had signatory authority. For example, on
June 19, 1990, petitioner deposited $15,000 in traveler’s checks
into Bank of Milpitas account No. 512-001-300466. Likewise, on
July 18, 24, and 26, 1990, petitioner deposited cash into this
same bank account in the respective amounts of $9,600, $9,700,
and $9,800.
After depositing some of the aforementioned moneys,
petitioner wrote checks to Alviso or GMT noting on the checks
that these payments were loans. For example, on or about
November 19, 1990, Transamerica Insurance Group issued a check
payable to Alviso for $67,256. On December 13, 1990, petitioner
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