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proceeds (money-laundering). The indictment alleged, inter alia,
(1) that beginning on or about January 1, 1985, and continuing
through April 15, 1989, Rayful Edmond III and Tony Lewis operated
a large scale unlawful narcotic drug trafficking organization and
(2) that shortly after C & I began operating Linea Pitti, peti-
tioner (a) maintained customer accounts at Linea Pitti for the
benefit of Rayful Edmond III and Tony Lewis on which purchases of
merchandise and payments thereon were recorded; (b) assisted them
in laundering the proceeds from their unlawful narcotic drug
organization in the purchase, on account and with cash, of in
excess of $400,000 worth of merchandise from Linea Pitti; and (c)
assisted them in further laundering their narcotic drug organiza-
tion's unlawful proceeds in the purchase of luxury automobiles
with those proceeds and in registering the automobiles in peti-
tioner's name as nominee.
On October 15, 1991, petitioner was convicted of 34 of the
counts set forth in the indictment, including about half of the
counts involving money-laundering. On appeal, the U.S. Court of
Appeals for the District of Columbia Circuit affirmed as to 32 of
those counts, but reversed as to two counts of illegal struc-
turing of financial transactions under 31 U.S.C. section 5324
(1994).
OPINION
Petitioner has the burden of showing that respondent's
determinations in the notice for 1986 that remain at issue are
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