Elizabeth Lai - Page 10

                                       - 10 -                                         
          content of the second set of letters was authentic and that the             
          letters were written by their purported authors.                            
               At all stages of the examination, progress was significantly           
          hampered by misunderstandings due to language barriers, poor                
          translations, cultural differences between petitioner and                   
          respondent’s employees, and petitioner’s somewhat guarded                   
          approach towards government officials.  For example, petitioner             
          originally told Agent Cedergreen that she did not receive any               
          loans during 1999 despite the fact that she simultaneously                  
          volunteered the existence of her Key Bank accounts which                    
          contained significant, unexplained deposits which she would later           
          attribute to intrafamily loans.  At subsequent meetings,                    
          petitioner offered Agent Cedergreen detailed information on                 
          several loan transactions, apparently without believing that the            
          information contradicted her previous statements.                           
          The Notice of Deficiency                                                    
               In a notice of deficiency dated October 5, 2004, respondent            
          determined deficiencies and penalties as stated supra.  Aside               
          from those adjustments which the parties have conceded, the                 
          deficiencies are composed of four elements:  (1) Inclusion of               
          petitioner’s additional bank deposits as unreported income for              
          each year; (2) inclusion of $9,760 of cash income for each year;            
          (3) inclusion of the amount of the cash used to purchase the                
          cashier’s check in gross income for 2000; and (4) adjustments to            

Page:  Previous  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  Next 

Last modified: November 10, 2007