- 9 - On or about August 19, 2003, petitioner hired C.P.A. Jerry Levey to help represent her during the examination. On October 29, 2003, petitioner provided Agent Cedergreen with 50 additional letters (the second set of letters). The letters indicate that some of petitioner’s friends and family in Vietnam sent cash to petitioner for safekeeping or investment in anticipation of their immigration to the United States. According to the letters, friends and family of petitioner who traveled from Vietnam to the United States would deliver the money to petitioner in amounts ranging from $3,000 to $17,000. Petitioner subsequently discovered that the first set of letters was not written by their purported authors. Shortly after she received the original letters in the mail, petitioner gave them to her mother to read and store. When petitioner asked her mother for the letters during the examination of her returns, petitioner’s mother could not find them and instead attempted to replicate the originals. Petitioner’s mother attempted to reconstruct the loan amounts mentioned in the letters from memory. When petitioner learned of her mother’s actions, petitioner promptly notified Mr. Levey of her discovery, and petitioner and Mr. Levey subsequently informed respondent that the first set of letters was authored by petitioner’s mother. Petitioner maintained at both the audit and at trial that thePage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: November 10, 2007