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concerning the U.S. dollar-CFA franc exchange rate to both Mr.
Emmanuel and the designated recipient of the CFA francs in
Cameroon; Mr. Emmanuel then paid the designated recipient of the
CFA francs in Cameroon the equivalent amount of CFA francs in
cash; and petitioner later purchased various items in the U.S.,
such as cars and computers, and shipped them to Mr. Emmanuel.
Petitioner asserts that he did not charge a fee for his
services. Three witnesses testified on petitioner’s behalf that
they engaged petitioner’s services, free of charge, in the
exchange of U.S. dollars for CFA francs. None of the witnesses
provided any documentary evidence to support the testimony.
As an example of the final step in the currency exchange
transaction petitioner presented some documents and testimony of
items purchased and sent to Cameroon. Petitioner purchased a
Jeep Cherokee in Virginia for approximately $20,000 in March or
April 1996. He paid for the Jeep Cherokee with cash that he
either kept in his house or withdrew from one of his bank
accounts in increments of $2,000 or $3,000. At trial petitioner
was unable to indicate which withdrawals or cash received from a
deposit reflected on his bank account statements were used to pay
for the Jeep Cherokee. Petitioner produced a bill of lading
reflecting the shipping of the Jeep Cherokee from the U.S. to
Cameroon in November 1996. Mr. Emmanuel’s name does not appear
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