Jerry Lee Harvey - Page 16




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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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