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Polaris continued to issue every six months checks that were
payable to Mr. Thompson with respect to Mr. Thompson’s invest-
ment.
On January 31, 1995, Polaris issued a $4,962.50 check
payable to Mr. Thompson (January 31, 1995 check). Petitioner
negotiated the January 31, 1995 check at First Bank.
On July 31, 1995, Polaris issued a $4,962.50 check payable
to Mr. Thompson (July 31, 1995 check). Petitioner, Ms. Thompson,
and Donald D. Kallestad (Mr. Kallestad), whom Weavewood employed
during 1995 and 1996, endorsed the July 31, 1995 check. On a
date not disclosed by the record between July 31 and August 4,
1995, petitioner negotiated the July 31, 1995 check by giving it
to Mr. Kallestad as a loan. On August 4, 1995, Mr. Kallestad
deposited that check into his personal checking account (Mr.
Kallestad’s personal checking account) at Norwest Bank-Minneapo-
lis. Approximately two or three months after Mr. Kallestad
deposited the July 31, 1995 check into Mr. Kallestad’s personal
checking account, Mr. Kallestad gave petitioner $4,962.50 in
repayment of the loan that he received from petitioner.
On January 31, 1996, Polaris issued a $4,962.50 check
payable to Mr. Thompson (January 31, 1996 check). Petitioner
negotiated the January 31, 1996 check.
On July 31, 1996, Polaris issued a $4,962.50 check payable
to Mr. Thompson (July 31, 1996 check). Petitioner negotiated the
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