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for personal items such as groceries, gas for her car, and other
needs amounted to $9,760 during 1999.
At some point after this meeting, respondent expanded the
scope of the examination to include petitioner’s 2000 and 2001
returns.
Agent Cedergreen met with petitioner, Mr. Nguyen, and Bob
Bradley (who was also representing petitioner), at respondent’s
Portland, Oregon, office on August 14, 2003. At this meeting,
petitioner again explained that the large deposits into her
personal accounts represented loan proceeds and loan repayments
from friends and family. Petitioner estimated that she received
more than $70,000 in loans in 2000 and more than $120,000 in
loans in 2001.
During the meeting of August 14, 2003, Agent Cedergreen
questioned petitioner about her purchase of a cashier’s check on
September 29, 2000. Petitioner initially did not remember that
she purchased a cashier’s check in 2000 or 2001 and stated that
she did not make such a purchase. After further questioning,
petitioner recalled that she purchased a cashier’s check on
behalf of Ms. Birkenfeld for the purpose of purchasing a
residence in which Ms. Birkenfeld would live. Petitioner
recalled that Ms. Birkenfeld agreed to give the house to Hong Lai
when Hong Lai came to the United States.
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