Don A. Chan and Cecilia Chan - Page 22

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                  Individual petitioners presented a complicated system of                               
            recordkeeping used by Shin to avoid reporting the deposited                                  
            amounts as income.  They contend that Shin shareholders and                                  
            employees borrowed money from the Coast and First Pacific                                    
            accounts and repaid Shin in Taiwanese currency within a short                                
            period of time.  Shin permitted the alleged borrowers to retain                              
            any benefit they received from a favorable street rate.  Shin                                
            recorded the repayments as an inflow from a shareholder; thus, on                            
            Shin's books, it would appear as if the money was due back to a                              
            shareholder.  However, Shin did not record the names of the                                  
            shareholders that made the alleged advances.  Once the payments                              
            were recorded on Shin's books, Shin would use the money to pay                               
            farmers and seasonal workers with cash.  Shin recorded the                                   
            payments to the farmers and workers as outflows to shareholders.                             
            Thus, it would appear as if the shareholders were repaid for the                             
            fictitious advances.                                                                         
                  We do not believe that individual petitioners created this                             
            elaborate scheme to benefit Shin without any expected benefit to                             
            Eastimpex or themselves.  Nor do we fully believe that Shin used                             
            the deposited amounts to pay farmers and seasonal workers or that                            
            Shin's shareholders ever repaid Shin for the money it gave them.                             
            Substantial amounts from the accounts were dispersed to or for                               
            the benefit of family members of individual petitioners who did                              
            not reimburse Shin.                                                                          






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