Elizabeth Lai - Page 9

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               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 the               

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