Marcel Toto Ngosso - Page 5

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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.                    
               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´┐Ż,              
          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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