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In order to prepare for the hearing in Florida, Kibort
continued to follow up on several leads. At petitioner's bond
hearing, Kibort learned from Young's testimony that petitioner
had transferred money to Panama. Kibort also learned that a
$65,000 check payable to petitioner from Ellis was negotiated at
BCCI in Panama. Furthermore, Kibort learned that when petitioner
was arrested in St. Louis, he had in his possession a business
card of his banker, Hussain, who was an employee of BCCI, and an
address book that showed the account No. ML-49 on one of the
pages. Kibort also discovered, through FAA records, that
petitioner had sold another aircraft in 1985 for $700,000, and
$670,000 of that was wired to BCCI in Panama to account No. ML-
49.
All this information Kibort was gathering was solely in
preparation for the hearing regarding the termination
assessments. Kibort was not working on anything related to
petitioner's criminal tax prosecution. The District Court upheld
the termination assessments in October 1987.
After the decision on the termination assessments was
received, Kibort considered initiating a jeopardy assessment that
would cover the taxable years for which petitioner was under
criminal tax investigation. In order to do the jeopardy
assessment, Kibort needed the approval of several high officials
in the IRS, including someone representing the Collection
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