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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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