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indicated that petitioner was an adept pilot, had experience with
international travel, possessed high-quality counterfeit
identification, and held property in corporate names.
Kibort found this information he obtained at the bond
hearing very significant in making a termination assessment.
Kibort's inquiry into petitioner's civil tax liability did not
end, however, with the information obtained from the proffer at
the bond hearing. Kibort contacted Bill Walker & Associates,
which was a brokerage firm on St. Simons Island, Georgia. Kibort
learned that Bill Walker & Associates paid petitioner the three
checks in his possession at the time of his arrest, in addition
to two other checks and some currency.
Kibort also contacted an individual named Rafael Ellis
(Ellis) in Oklahoma City, Oklahoma. Ellis represented a
Brazilian corporation that purchased the aircraft at issue.
Ellis told Kibort that petitioner wanted the purchase price in
currency. Ellis did not want to pay the purchase price in
currency, so petitioner gave him the option of wire transferring
the purchase price to petitioner's bank account, No. ML-49, at
BCCI in Panama. Petitioner also told Ellis that his banker was
an individual named Syed Aftab Hussain (Hussain).
Since Kibort now knew the sale price of the aircraft from
the checks and currency, his next goal was to determine
petitioner's basis in the aircraft. Kibort discovered the
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