Tommy Ho Ching Cheng - Page 2

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          decision are:  (1) Whether the Court should reconsider its denial           
          of petitioner’s fourth motion for continuance; (2) whether the              
          statute of limitations under section 6501(a) bars the issuance of           
          a notice of deficiency; (3) whether petitioner has an income tax            
          deficiency for 1996; and (4) whether petitioner is liable for an            
          addition to tax under section 6651(f).                                      
                                  FINDINGS OF FACT                                    
               At the time the petition was filed, petitioner resided in              
          Diamond Bar, California.                                                    
               Petitioner was born in Hong Kong in 1951 and moved to the              
          United States in 1982.  Petitioner resided in the United States             
          from 1982 until his deportation on March 17, 2005.                          
          A.   Petitioner’s Business Activities                                       
               During 1996, petitioner earned income from his trade or                
          business of obtaining U.S. passports and Republic of Marshall               
          Islands (Marshall Islands) passports for various individuals.               
          Petitioner also sought foreign investors for his trade or                   
          business and used their investments as a basis for obtaining                
          marketing investment visas which would allow the foreign                    
          investors to visit the United States.                                       
               During 1996, petitioner deposited funds received from his              
          business activities into seven bank accounts.  Four of these                
          accounts were in petitioner’s name, three at Cathay Bank (the               
          Cathay Bank accounts) and one at Bank of America (the Bank of               






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