-14-
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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