Chong-Kak and Sang-Ok Lee - Page 16

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               Petitioners also rely on the fact that the Lees hired a law            
          firm allegedly to recover the stolen funds.  We give this fact              
          little weight.  The law firm merely mailed demand letters to                
          Mr. Won and his brother, and neither the firm nor the Lees took             
          any meaningful steps, after these letters were mailed, to recover           
          the amounts claimed stolen.  The Lees, for example, could have              
          (but did not) seek criminal charges against Mr. Won or his                  
          brother with respect to the alleged theft.  The Lees also could             
          have (but did not) make a claim on Hamalee's then-existing                  
          insurance policy.  While we can understand the delicate and                 
          difficult familial situation that the Lees may have faced with              
          regard to criminally prosecuting their daughter's husband with              
          respect to this purported matter, we cannot excuse the lack of              
          evidentiary support for the claimed thefts.  Petitioners have not           
          convinced us that these "thefts" occurred.                                  
               Because petitioners have failed to disprove respondent's               
          determination on this issue, we sustain it.                                 
          3.  Unreported Cash Expenditures                                            
               Petitioners argue that Hamalee may deduct certain cash                 
          expenditures that were made in each year in issue, but for which            
          Hamalee did not claim a deduction on its corresponding tax                  
          returns.  Petitioners allege that these cash expenditures were              

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