Kaing Chin and Hae Kyung Baek - Page 7

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          account, of which the $126,646.80 is part, included (1) most of             
          the $81,511.64 that was received from the checks cashed by Beak             
          at the establishment and (2) other amounts that Yoo gave Baek in            
          repayment of funds that Baek, either directly or indirectly,                
          caused to be received by Yoo.  We hold for petitioners.                     
               All arguments in this case have been considered, and those             
          arguments not discussed herein have been found to be without                
          merit or inapplicable to our decision.                                      
                                                  Decision will be entered            
                                             for petitioners.                         





























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