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Belle Vie bank accounts. Petitioner also received tips from her
work at La Belle Vie during 1999, 2000, and 2001.
Petitioner’s Banking and Investment Accounts
During 1999, 2000, and 2001, petitioner maintained bank
accounts at both Key Bank and U.S. Bank. She maintained two
checking accounts at Key Bank in her own name. Petitioner
maintained a checking account at U.S. Bank under “La Belle Vie”
and a money market account under “Elizabeth T. Lai Sole Prop La
Belle Vie”. Petitioner used the Key Bank accounts as her
personal accounts and the U.S. Bank accounts as her business
accounts.
Petitioner deposited and withdrew money from her personal
accounts at Key Bank as follows:
Year Cash Deposits Total Deposits Withdrawals
1999 $85,590.88 $113,766.37 $116,275.50
2000 63,300.00 94,096.74 95,728.48
2001 112,800.00 151,145.22 135,502.02
Petitioner’s withdrawals from her personal accounts at Key Bank
included payments for home and car loans, utilities, clothes, and
other personal expenditures.
Petitioner’s Purchase of a Cashier’s Check in 2000
On September 29, 2000, petitioner used cash to purchase a
cashier’s check of $55,204 from U.S. Bank. Petitioner did not
withdraw the $55,204 that she used to purchase the cashier’s
check from any of her personal or business accounts. Petitioner
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