Big Hong Ng - Page 14

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          United States. The parties stipulated that $530,603 in                      
          disbursements from the tip account between 1986 and 1989 were paid          
          to Ocean City Restaurant in San Francisco, in which Ms. Ng had a 5-         
          percent ownership interest, or to its suppliers.  Accordingly we            
          find, and thus hold, that only 5 percent of the $530,603 deposited          
          into the tip account was income to Ms. Ng.                                  
               The parties also agreed that $473,660 was paid directly to Ms.         
          Ng from the tip account. Ms. Ng claims that some of the $473,660            
          went to Ocean City Seattle and Ocean City San Francisco, as well as         
          to the Golden Palace Restaurant in Los Angeles, in which she had no         
          ownership interest.  Other than an exhibit showing that a $50,000           
          withdrawal from the tip account on November 30, 1987, was recorded          
          on the books of Ocean City HK as a loan to the Golden Palace, Ms.           
          Ng presented no evidence that any specific disbursement went to any         
          of these restaurants.  The funds were wired directly to Ms. Ng, and         
          there is no evidence that she transmitted the money to the Golden           
          Palace. Accordingly, we find, and thus hold, that all of the                
          $473,660 paid directly to Ms. Ng from the tip account is income to          
          her.                                                                        
               The parties agreed that $4,409 was paid from the tip account           
          to Golden Dragon Restaurant or its suppliers.  Ms. Ng is a 50-              
          percent owner of the Golden Dragon, and we find, and thus hold,             
          that half of this $4,409 is income to her.                                  
               The parties stipulated that $18,092 was disbursed from the tip         
          account to pay Ms. Ng's personal credit card bills.  We find, and           




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