- 8 -
introduced at trial. Two checks (one from October 9, 1989,5 in
the amount of $10,000, and one from March 12, 1990, in the amount
of $10,000) were made out to Dr. Chan as payee. The second of
these checks has written in the "Description" area "Reimburse -
Training". Dr. Chan claims that he had, on these two occasions,
paid petitioner with a personal check, and then Shanghai reim-
bursed him for the cost of the lessons. Five checks, totaling
$65,000, were made out to Yao Min Ting. The first check, dated
April 9, 1990, was in the amount of $15,000, and included the
notation "Business Consulting" in the description line of the
check. The second check, dated May 9, 1990, was in the amount of
$15,000 was also described as a "Business Consulting" fee. The
third check, dated June 9, 1990, was for $15,000 and was
described as a "Business Consulting Fee". The fourth check,
dated November 30, 1990, was for $10,000 and was described as a
"Consultation" fee. The fifth check, dated January 31, 1991, was
for $10,000 and was again described as a "Consultation" fee.
Three checks, totaling $25,600, were made out to Ting Yao Min.
The first, on June 25, 1990, was for $15,000 and was described as
a business consultation fee. The second dated August 8, 1990,
was for $10,000. The third check, dated September 17, 1990, was
for $600 and was described as a consultation fee. One wire
5We note that the 1989 tax year is not herein in issue.
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