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Please forward to Bruce Campbell & Co. a draft in
favour of Canadian Imperial Bank of Commerce for the
sum of US$3,125,000.00, the balance on the account
should be handed to the bearer of this letter in cash.
These sums represent the six Certificates of Deposit
held at your branch and which mature today.
Bruce Campbell & Co. was the law firm petitioner used in the
Cayman Islands. In addition, attached to the brief was a copy of
the referenced check payable to the Canadian Imperial Bank of
Commerce. Springer had a copy of this brief and sent it to
Kibort in October 1987.
To make the jeopardy assessment, Kibort also needed to
obtain the permission of the CID. Kibort needed permission from
the CID to ensure that he was not taking any action that would
harm the pending criminal case. Kibort flew to Florida to meet
with Young, Revenue Agent Charlie Parenteau (Parenteau), and
others. The meeting entailed solely a presentation by Kibort as
to what he proposed to do as a computation to determine a
liability. Young, Parenteau, and the others present at the
meeting did not provide Kibort with any information. The CID
approved the jeopardy assessment. On December 10, 1987, the
assessment was made and levies were served against BCCI branches
in Miami and New York.
Kibort computed the tax for the jeopardy assessment using,
in part, the expenditures method based on the list of the 46 paid
bank drafts attached to the brief he received from Springer.
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