Jerry Lee Harvey - Page 19




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          Division.  The Collection Division would want assurance that the             
          assessment would result in a high probability of collection.                 
               Kibort went to the IRS District Counsel in St. Louis and                
          discussed with him whether the IRS could reach petitioner's money            
          in Panama through a domestic branch of BCCI.  The St. Louis                  
          District Counsel referred Kibort to Jim Springer (Springer) at               
          the Department of Justice.  Springer had just finished a similar             
          case, where overseas funds were sought from an international bank            
          through a domestic branch.  Springer advised Kibort that he would            
          send him information regarding that action.                                  
               Springer was also familiar with petitioner.  While                      
          petitioner's criminal tax prosecution in Florida was pending,                
          petitioner filed a motion opposing admission in evidence of                  
          foreign records, specifically records regarding petitioner                   
          obtained from the Government of the Cayman Islands.  The                     
          Government opposed petitioner's motion.  Attached to the                     
          Government brief in opposition was a list of 46 paid bank drafts             
          from petitioner's bank accounts at the Bank of Nova Scotia in the            
          Cayman Islands.  The final bank draft was paid on July 28, 1983,             
          to the Canadian Imperial Bank of Commerce in the amount of                   
          $3,125,000.  Also attached to the brief was a July 25, 1983,                 
          letter to the manager of the Bank of Nova Scotia, signed by                  
          petitioner, that stated:                                                     







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