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Examination of Petitioner’s Income Tax Returns
Petitioner’s 1999 income tax return was selected by
respondent for examination. Revenue Agent Daren Cedergreen
(Agent Cedergreen) conducted the examination, which began in
2002.
On February 14, 2002, Agent Cedergreen met with petitioner
and Mr. Nguyen, who agreed to represent petitioner during the
examination, at La Belle Vie. During that meeting, petitioner
stated, inter alia, that all her income came from La Belle Vie,
that she did not have a safe deposit box, and that she did not
receive any loans during 1999.
On September 23, 2002, Agent Cedergreen met again with
petitioner and Mr. Nguyen at Mr. Nguyen’s office. During that
meeting, petitioner stated that the deposits in her Key Bank
accounts represented loan proceeds and loan repayments from
family and friends in the United States and Vietnam. Petitioner
also said that she maintained a safe deposit box at Key Bank.
At the meeting, petitioner showed Agent Cedergreen seven
letters (the first set of letters) that she believed were
authored by relatives and acquaintances. The letters, many of
which are written in Vietnamese, discuss loans between petitioner
and her friends and family made during late 1998 and 1999.
During the meeting of September 23, 2002, petitioner filled
out a questionnaire indicating that her routine cash expenditures
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