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was, who determined it, or how it was determined. Her testimony
with respect to the purported loans by NCPL to petitioner
conflicted, in part, with other evidence.19 Additionally, she was
unable to recall who drafted her Officer’s Certificate dated
November 21, 2006, but when pressed on cross-examination, admitted
receiving the document from petitioner. Ms. Chen provided no
books or records from NCPL to substantiate any of her testimony,
and the only documents bearing her signature were documents
written in English.
Ms. Chen attempted to avoid answering questions directly put
to her, she lacked basic knowledge about NCPL and its relationship
to petitioner, and her demeanor at trial led the Court to believe
she would sign any document placed before her by petitioner.
Therefore, the Court finds that her testimony was not credible.
II. The Purported Loans
Respondent contends petitioner failed to report the following
wire transfers as income:
19 Ms. Chen testified that the amounts advanced for the
divorce and the improvements on the Rivercliff property were
$80,000 and $550,000 respectively. Her testimony with regard to
the $510,000 to $520,000 advanced to purchase the Rivercliff
property was accurate.
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