Dennis J. Tang and Alice Shu-Ling Tang - Page 9

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          transfer of $10,800 was sent to the account of Tang Chiang Ting6            
          on April 2, 1990.  Dr. Chan claimed that, in April and September            
          1990, he paid petitioner $15,000 and $10,000,7 respectively, as             
          compensation for lessons.  No checks were presented to                      
          corroborate this claim.  Shanghai Clinic deducted its expenses              
          for these lessons as educational and business expenses on its               
          corporate returns.                                                          
               Yao Min Ting visited the United States during 1989 and 1990.           
          He visited petitioners several times during 1990.  He maintained            
          a bank account at Sumitomo Bank.  A signature card from Yao Min             
          Ting's account at Sumitomo Bank of California lists petitioners'            
          address, 616 Winthrop Road, San Marino, California, as his own.             
               Petitioner testified that, in 1990, Dr. Chan offered, merely           
          as a sign of gratitude on his own volition, to write petitioner a           
          check for any amount petitioner requested.  Instead, petitioner             
          instructed Dr. Chan to show his gratitude by sending a gift or              

          6The record does not reveal who Tang Chiang Ting is or his                  
          relationship with petitioners.  However, one of the signatories             
          on Tang Chiang Ting's account at Sumitomo Bank, to which Shanghai           
          Clinic transferred $10,800 in payment for Dr. Chan's lessons, was           
          Jung Chu Fang.  Jung Chu Fang also is one of the signatories on             
          petitioners' bank account at Sumitomo Bank.  Furthermore, on                
          Apr. 2, 1990, the same day as the wire transfer of $10,800 from             
          Shanghai Clinic to Tang Chiang Ting's account, Jung Chu Fang                
          wrote a check from Tang Chiang Ting's account to Alice Shu-Ling             
          Tang for $10,000, ostensibly as a repayment of a loan.                      
          7When questioned by respondent at trial, Dr. Chan could not                 
          remember how much he paid petitioner in September 1990 for a                
          lesson.  He testified that he thought the amount paid was either            
          $10,000 or $11,000.  No further evidence as to the amount of this           
          payment was brought forth.                                                  




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