Big Hong Ng - Page 3

          negligence, substantial understatement, failure to file timely              
          returns, and failure to pay estimated tax; (8) whether Strong Hope          
          had discharge of indebtedness income; (9) whether Strong Hope's             
          basis in certain real estate that it transferred should be adjusted         
          as determined by respondent; (10) whether respondent properly               
          disallowed a net operating loss carryover to Strong Hope; and (11)          
          whether Strong Hope is liable for an accuracy-related penalty and           
          for an addition to tax for failure to file a timely return.                 
               All section references are to the Internal Revenue Code for            
          the years under consideration.  All Rule references are to the Tax          
          Court Rules of Practice and Procedure.                                      
               Some of the facts have been stipulated and are so found.  The          
          stipulations of facts and the attached exhibits are incorporated            
          herein by this reference.                                                   
               Ms. Ng, also known as Don Hong Ng, Bik Hung Ng Leong, and              
          other names, resided in San Francisco, California, at the time she          
          filed her petition. Ms. Ng's tax returns for all years under                
          consideration were untimely filed.                                          
               Ms. Ng was born in 1935 and came to the United States from             
          Hong Kong in approximately 1958. She studied English and music in           
          the United States, and became a resident alien shortly after her            
          marriage in 1962 to Sik Chong Leong in Reno, Nevada. They were              
          divorced in 1968 and had no children. Ms. Ng acquired her U.S.              
          citizenship in 1966.  Ms. Ng has a son, Timothy Lee, who was born           

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