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Ms. Ford also transferred large sums of money among her
various personal accounts during 1986. On August 11, 1986, she
wrote a check for $286,000 from her personal account at Security
Pacific National Bank, made payable to Security Pacific National
Bank, with a notation that it was for a cashier’s check. On
August 27, 1986, Ms. Ford wrote another check from her Security
Pacific account, this time payable to “Cash”, for $346,290.78.
On April 15, 1986, Ms. Ford deposited a check for $55,074 from
her brokerage account at Yorkton Securities, Inc., into her
account with the National Bank of Canada. On February 9, 1986,
Ms. Ford wrote a check for $10,000 to Codowell S.A., in
Switzerland. Less than a year after signing her 1986 return, on
April 12, 1988, Ms. Ford sent a handwritten letter to the
managing director of the TSB Private Bank International S.A., in
Luxembourg, requesting that $100,000 be placed in a high-yield
account for her.
On or about June 19, 1986, Ms. Ford purchased a house in
Montecito, California, for $1,150,000. Ms. Ford borrowed
$1,150,000 from the Maryland Bank International N.A. in
Luxembourg to make the purchase, signing documents for a deed of
trust to the Maryland Bank. The downpayment was taken from the
Canadian brokerage account of one of the nominee corporations,
and the Maryland Bank loan was guaranteed by another nominee
corporation’s trading account. Ms. Ford made no monthly payments
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