Big Hong Ng - Page 10

          apparent from records and documents summonsed from Hong Kong after          
          the notice of deficiency was issued and certain other items                 
          ultimately substantiated by Ms. Ng.                                         
               During a July 22, 1991, interview, Ms. Ng told the revenue             
          agent that she had only one foreign bank account from 1986 through          
          1989, and that only her salary from Ocean City Restaurant and Night         
          Club, Limited in Hong Kong (Ocean City HK) was deposited into that          
          account.  In response to a discovery request, Ms. Ng's counsel              
          informed respondent that Ms. Ng had signature authority over 2              
          foreign accounts, one account at Hang Seng Bank and one account at          
          Wing Lung Bank, which belonged to Ocean City HK.  Ms. Ng refused to         
          consent to the release of her foreign bank records until ordered to         
          do so by the U.S. District Court for the Northern District of               
          California.  The revenue agent ultimately discovered, and obtained          
          records showing, that Ms. Ng had one account at Hang Seng Bank and          
          six accounts at Wing Lung Bank.  The additional income asserted in          
          the amended answer involves deposits to Ms. Ng's bank accounts at           
          Hang Seng Bank and Wing Lung Bank.                                          
               The revenue agent also analyzed Ms. Ng's cash expenditures.            
          Those expenditures that could not be traced to a nontaxable source          
          or reported income were considered unreported income.  For example,         
          the revenue agent included $45,568.68 as unreported income for              
          1988, which was the amount Ms. Ng paid in cash for a cashier's              
          check on July 5, 1988, because the revenue agent could not trace            
          that cash purchase to a nontaxable source.                                  

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