                                 T.C. Memo. 2007-12                                   


                               UNITED STATES TAX COURT                                


                       YUNG AND ANITA F. CHONG, Petitioners v.                        
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 19581-04.            Filed January 17, 2007.                


               Yung and Anita F. Chong, pro sese.                                     
               Rebecca Duewer-Grenville, for respondent.                              


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               HOLMES, Judge:  Yung Chong gave money to his brother to help           
          open a business in Beijing.  He had another business in this                
          country, and he and his wife, Anita, claimed large deductions on            
          their 1998 tax return for losses from both.  The Commissioner               
          disallowed almost all of them due to a near complete lack of                
          records.  The Chongs blame this in part on a catastrophe suffered

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