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included the Shanghai Banking Corp. at the Harcourt Road branch,
the Hong Kong Bank at the Harcourt Road branch, and the CITIC Ka
Wah Bank.
On April 2 and 6, 2004, Agent Rans mailed petitioner Forms
4564 requesting: (1) A narrative explanation from petitioner’s
employer regarding his understanding of his joint ownership in
the Rivercliff property and the terms of the loan agreement; (2)
a narrative explanation from petitioner’s employer stating “why
they are currently paying the interest, and ultimately, the
principal on the $1,400,000 settlement that you owe to your ex-
wife, Kumiko” and why they were paying petitioner’s daughter’s
tuition at BYU; (3) the address, telephone number, and passport
number for petitioner’s employer, Mr. Chen; (4) an explanation of
why NCPL did not have a security interest in the Rivercliff
property until after TPPL and NCPL had advanced approximately $5
million; and (5) an explanation of why monthly wire transfers
from NCPL to petitioner for petitioner’s spousal and child
support obligations did not constitute taxable income.
Petitioner did not provide the requested information
regarding his employer or his employer’s narrative explanation
with respect to the joint ownership of the Rivercliff property,
the terms of the loan agreement, and the interest payments on the
$1,400,000 settlement judgment.
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