It may be that as all banks have had to accumulate capital and control their costs on expenses and headcount any operation that is making a profit is encouraged to keep up the good work.
Petitioner used profit and loss statements prepared with QuickBooks, but there is scant evidence that petitioner used them for the important purposes of cutting expenses, increasing profits, and evaluating the overall performance of the operation.
Secondly, this must have been a very well financed and orchestrated operation: where did they get the funding to travel to Brazil, then Peru and while there have cash for expenses?