Elizabeth Lai - Page 15

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               In addition to her own testimony, petitioner offered                   
          testimony from her sisters Hong Lai and Sharon Huynh, and her               
          daughter Victoria Lai Hutchins to support her contention that the           
          deposits into her personal accounts represent loan proceeds and             
          repayments from intrafamily loans.  Petitioner also offered the             
          second set of letters that she gave to Agent Cedergreen during              
          the examination of petitioner’s 1999, 2000, and 2001 income tax             
               Petitioner, Hong Lai, Sharon Huynh, Victoria Lai Hutchins              
          all testified that petitioner participated in several intrafamily           
          loans during the years at issue in an effort to help family                 
          members establish financial stability as they arrived and settled           
          in the United States.  Petitioner testified that she deposited              
          the proceeds of several loans into her personal accounts during             
          the years at issue.  Hong Lai, who had indepth knowledge of her             
          extended family’s financial affairs, corroborated that several              
          letters from the second set were authentic and that she                     
          recognized the handwriting and signatures of her sisters in                 
          Vietnam on 31 of the letters.6  Sharon Hunyh’s and petitioner’s             
          testimony regarding the letters corroborated Hong Lai’s                     

               6  Although petitioner’s witnesses testified that additional           
          letters were authentic, some pertain to loan transactions that              
          occurred in years other than the years at issue.                            

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