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6. Camaro’s Transfer of $5,000 to Hudson (Petitioner’s
Niece)
On December 5, 1988, petitioner told Choy to have HSBC issue
a $5,000 check to petitioner’s niece, Hudson, from Camaro's HSBC
U.S. dollar-denominated savings account. On December 19, 1988,
Hudson deposited the HSBC check in her credit union account.
Hudson died in July 1994. By letter dated August 30, 1994,
petitioner stated that he had lent her $5,000 and demanded that
Hudson’s estate repay that amount.
7. Transfer of $10,000 From Camaro to Sylvia Mangin
On May 26, 1988, pursuant to petitioner’s instruction to
Choy, Camaro transferred $10,000 from its U.S. dollar-denominated
savings account to Sylvia Mangin to pay the expenses of a ski
trip taken by the Mangins and petitioner’s family.
I. Petitioners’ Tax Returns
1. Petitioners’ Tax Return Preparer
Sidney R. White (White), C.P.A., prepared TCM’s and
petitioner’s tax returns for 1987 and 1988 and petitioner’s
amended tax returns for 1987 and 1988. Petitioner gave White the
information he used to prepare those returns. Petitioner did not
give White records of any of the Camaro accounts. Petitioner did
not tell White that TCM had sent NSA checks to Hong Kong or that
petitioner had signature authority over any Camaro accounts.
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