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to Constance Njombua Toto Ngosso.3 Petitioner’s bank account
records, however, do not clearly indicate that petitioner
withdrew funds or wrote checks for the exact or similar amounts
to support his theory that he acted as a conduit for Mr.
Diomande.
Petitioner reported $7,700 in gross income on Schedule C,
Profit or Loss From Business, attached to his Federal income tax
return for the 1996 tax year. Petitioner reported “Income Tax
Prep” as the principal business.
Petitioner, a native of the Republic of Cameroon, and Epee
Ndolo Emmanuel (Mr. Emmanuel), his uncle who lives in Yaound�,
Cameroon, engaged in a series of transactions in which they
effectively exchanged U.S. dollars for Cameroonian francs (CFA
francs) for the benefit of friends, business associates, and
strangers. Petitioner engaged in a “currency exchange
transaction” and explained it as follows: Petitioner received a
sum of U.S. dollars in cash from an individual who desired to
send money to a third party in Cameroon; petitioner calculated
the equivalent amount of CFA francs using the exchange rate for
that day; petitioner either deposited the U.S. dollars he
received into one of two bank accounts or held the cash in his
house on behalf of Mr. Emmanuel; petitioner faxed the information
3 There is nothing in the record indicating that these
individuals are related to petitioner.
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