ON April 16, 1980, a man using the name Marvin Goldstein opened a bank account at a Baltimore branch of Union Trust Company. He deposited $15,000 in cash. He told the branch manager that he planned to establish a Baltimore office of his father's New York business, "Goldstein's Precious Metals and Stones." Goldstein identified himself with a New Jersey driver's license and gave a bank reference from New York. On May 6, Goldstein deposited a check for $880,000 at another Union Trust branch near the branch where he had opened the account. Words on this check indicated that it was drawn on the account of Metropolitan Investment Corporation at First Pennsylvania Bank, a large Philadelphia bank. Unbeknownst to the Union Trust officers, the fractional numerals in the upper right hand corner of the check identified Albany State Bank as the payor, and the numerals at the bottom of the check were gibberish: they identified no bank at all. Apparently Goldstein had altered the numerals at the bottom for they were not magnetic numerals, were of the wrong size and were nonsensical. On most checks the name of the drawee, the fraction in the upper right hand corner and the Magnetic Ink Character Recognition ("MICR")-encoded numerals on the bottom-all identify a payor.
White, James J. "Goldstein's Curse." U. Tol. L. Rev. 21 (1990): 599-624.