Tobias G. Ogu - Page 9

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               E.  Petitioner’s “Overseas Expenses” in Nigeria                        
               On Part V of his Schedule C for 1999, petitioner claimed               
          under the category of “Other Expenses” a deduction for overseas             
          expenses in the amount of $24,720.  Petitioner did not break this           
          amount into constituent parts, but he did describe the total as             
          “overseas commission, shipping, office supplies, etc”.                      
               On Part V of his Schedule C for 2000, petitioner claimed               
          under the category of “Other Expenses” deductions for overseas              
          expenses as follows:                                                        
                         Deduction               Amount                               
                         Overseas rent           $3,900                               
                         Overseas expenses        7,870                               
                         Overseas wages          16,000                               
                         Overseas office          1,680                               
               The deductions for “overseas expenses” in 1999 and 2000                
          appear to relate to Americana Business Consultants (Nigeria)                
          Limited.                                                                    
               F.  Petitioner’s Involvement in State Court Litigation                 
               In September 1999, an individual by the name of Francis                
          Iheanacho (Mr. Iheanacho) commenced a civil action (Cause No.               
          1999-47585) in the District Court of Harris County (Houston),               
          Texas, against petitioner for libel and intentional infliction of           
          emotional distress.  Mr. Iheanacho named petitioner both                    
          individually and as agent and officer of Mbaise Cultural Union,             
          Inc., an organization described by petitioner as “a Houston based           








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