- 22 -
of petitioner's funds in Panama, Kibort and others requested
petitioner's bank records from BCCI.
Special Agent Pamela L. McCullough (McCullough) of the U.S.
Customs Service had been participating in criminal investigations
concerning Manuel Antonio Noriega (Noriega) of Panama, and
others, in narcotics trafficking and money laundering. These
investigations led to two indictments against Noriega, and
others, including BCCI, in the District Court for the Middle
District of Florida in Tampa. Following the investigations, as
part of a plea agreement, BCCI agreed to assist the Government in
obtaining banking records maintained in Panama.
In approximately April 1990, McCullough went to Panama and
presented the Panamanian Government with an affidavit to obtain
the records of Noriega and others, including petitioner.
McCullough included the request for petitioner's records at the
request of an IRS CID agent. Petitioner's records were obtained
from BCCI and were used to make the determinations in the notice
of deficiency issued to him for the years 1985 through 1989.
The $4,602,776.17 returned by BCCI was deposited by the
Clerk of the Court for the Southern District of Florida into an
interest-bearing account at NationsBank. In June 1992, the IRS
received, pursuant to an order of the District Court, a total of
$5,132,074.88 from the NationsBank account consisting of the
$4,602,776.17 originally received from BCCI together with accrued
Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 NextLast modified: May 25, 2011