-11-
Tip Account
One of the Hong Kong accounts the revenue agent examined was
referred to by the parties as the tip account. The reason for such
nomenclature is because the deposits into this account came from
tips paid to employees of Ocean City HK. Ms. Ng denies ownership
of this account.
Ocean City HK has seating capacity for approximately 5,000
people and is the largest restaurant in Hong Kong. Ms. Ng owned at
least a 4.5-percent interest in Ocean City HK and was employed
there as deputy managing director from 1978 until 1991. Her duties
included supervision of personnel, floor shows, and food
preparation. She signed checks on the restaurant's behalf but was
not involved in accounting.
Ms. Ng and her brother, Sik Yuen Ng, who also was employed at
Ocean City HK, opened the tip account at Wing Lung Bank on March
11, 1981. The account was in their names, and they each had
signature authority.
Deposits to the tip account from 1986 through 1990 were
generally in cash as follows:
Year Amount Deposited Number of Deposits
1986 $1,543,418 156 (6 noncash deposits)
1987 231,541 57 (3 noncash deposits)
1988 228,910 49 (all cash)
1989 567,919 36 (3 noncash deposits)
1990 5,301 1 (cash)
All the withdrawals from the tip account which the revenue
agent could trace were for the benefit of Ms. Ng or a restaurant
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