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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
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Last modified: November 10, 2007