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finish the final retitlement of the [Rivercliff]
Property * * *.
After discovering that substantial amounts were wire
transferred from NCPL’s and TPPL’s Hong Kong bank accounts to
petitioner’s and SSI’s bank accounts, on May 24, 2004, Agent Rans
mailed petitioner a Form 4564 with two consent directives for
petitioner’s signature. An attached letter stated:
Attached are two documents (consent directives) that I
would like you to sign and mail back to me. The
purpose of the documents is to send to the Hong Kong
and Shanghai Bank and the Citic Ka Wa bank in Hong Kong
to request records. You have stated that you have no
control over those accounts. In that case, the banks
would not have the authority to release the requested
records to me. This would possibly be one way of
verifying that you do not have control over these
accounts. Please call me if you have any questions
regarding this request.
Respondent was required to obtain consent to acquire the
information because the United States and Hong Kong do not have a
treaty allowing the IRS to subpoena a U.S. citizen’s bank account
information from Hong Kong banks.
In response, on May 30, 2004, petitioner mailed a letter
stating that he did not have an offshore bank account and his
employer prohibited him from signing the consent directives.
Petitioner returned the consent directive unsigned.
On September 9, 2004, petitioner and Ms. Chen, on behalf of
NCPL, executed a Memorandum of Confirmation and Agreement, which
states:
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Last modified: March 27, 2008