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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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