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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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