Marcel Toto Ngosso - Page 6

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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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