-6-
through an interpreter, we found that when using English to
testify, she did not have any difficulty.
For convenience and clarity, we have combined additional
findings of fact and opinion with respect to each issue.
Issue 1. Unreported Income
The largest adjustments to Ms. Ng's income are based on
respondent's determination that Ms. Ng failed to report substantial
amounts of income. Specifically, respondent determined that Ms. Ng
failed to report: (a) Self-employment income which was deposited
into bank accounts she controlled in the amounts of $54,849 in
1986, $50,444 in 1987, $563,513 in 1988, and $346,993 in 1989; (b)
income consisting of deposits from Hong Kong into bank accounts she
controlled, rental and interest income, and forgiveness of debt
income, not subject to self-employment tax in the amounts of
$168,300 in 1986, $247,761 in 1987, $170,545 in 1988, $212,459 in
1989, and $93,208 in 1990; and (c) income which was deposited into
the tip account, discussed infra, as well as other Hong Kong bank
accounts, in the amounts of $1,643,928 in 1986, $242,098 in 1987,
$245,355 in 1988, $719,163 in 1989, and $159,153 in 1990.
In the amended answer, respondent asserted additional
unreported income, totaling $3,271,690 for the 5 years under
consideration, from unexplained deposits to bank accounts in
foreign banks. Of this amount, at least $2,577,089 arises from
deposits to the tip account, discussed in detail, infra.
Respondent bears the burden of proof with respect to the increase
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011