Joseph D. and Mi Jung Park, et al. - Page 5




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               While petitioners felt a moral obligation to repay these               
          funds, neither Mr. Latief nor Mr. Tandiono ever asked for, or               
          expected, repayment or any interest in petitioners’ businesses.             
          John Park met with Mr. Latief on numerous occasions during the              
          years in issue.  During those meetings, Mr. Latief informed John            
          that he did not expect repayment.  Mr. Latief was insulted and              
          angry when John insisted on paying him back with interest, and              
          told John “this was not a business transaction.”  Similarly, when           
          David Park met with Mr. Tandiono, Mr. Tandiono did not want                 
          repayment, because he intended only to help David.  In addition,            
          Mr. Tandiono believed it was inappropriate to require repayment             
          from someone experiencing financial difficulties and that God               
          would bless him for helping someone in need.                                
               Respondent was suspicious of the inconsistencies between               
          petitioners’ lifestyles and their reported income and believed              
          petitioners were “skimming” money from several of their cash-               
          intensive businesses or from a Presbyterian church they                     
          established.  Initially, petitioners lied to respondent about the           
          source of their funds, saying they had received the funds from              
          their father.  Respondent was not satisfied with this response.             
          Petitioners eventually informed respondent that Mr. Latief and              
          Mr. Tandiono provided them with the funds.  Respondent’s Criminal           
          Investigation Division found no evidence of “skimming” and could            
          not disprove that Mr. Latief or Mr. Tandiono was the source of              






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