Introduction
This deportation proceeding began on January 28, 1977, when the respondent was served with an Order to Show Cause charging him with deportability under Section 241(a)(1) of the Immigration and Nationality Act (hereinafter, the INA), 8 U.S.C. §1251(a)(1), and Section 7(b) of the Refugee Relief Act of 1953 (hereinafter, the RRA), 67 Stat. 400, 404. An additional charge of deportability under 1§242(a)(2) of the INA was lodged at a later date. The record includes over 60 exhibits and 1400 pages of transcript. In light of the unusual nature and length of this proceeding, the service submits this post trial brief which summarizes: the allegations; the government's theory of the case; the evidence on both sides; and the legal issues involved.
I
THE ALLEGATIONS
Given the length to which the respondent has gone in attempting to disprove allegations not found in the Order to Show Cause, it is