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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Last modified: November 10, 2007