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evidence detailing his cash contributions, purchases, and
expenditures. Petitioner explained that he did not keep records
of his monetary contributions to KGT or JTW because in his home
country no one claims dependents on tax returns and no one
receives a refund of tax.
Petitioner offered into evidence only three receipts for
2003 to prove payments for KGT and JTW. None of them showed
exactly which amounts represented expenditures for either KGT or
JTW. Petitioner produced a Wells Fargo Bank transaction record
dated October 23, 2003, in the amount of $450; a self-prepared
receipt dated May 13, 2003, numbered 380499 in the amount of
$175; and a self-prepared, incomplete receipt dated August 23,
2003, numbered 380458 in the amount of $454 to substantiate his
cash payments.8 Petitioner generally did not use the receipts in
his receipt book in sequential order: “It’s a matter of opening
it up and writing. Then tear it out.”
Petitioner did not use the receipt book solely to
acknowledge his contributions or payment of money; he also used
it to acknowledge receipt of money. Petitioner explained that he
recorded amounts contributed in his receipt book and dated the
receipts the date on which he contends he gave money to Peter
8 The numbered receipts listed “Daniel Deng” on the
“Received From” line. Respondent stipulated that petitioner also
goes by the name “Daniel Deng”, “Daniel Deng McBol”, or “Daniel
Deng Aruai”.
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Last modified: May 25, 2011