-15-
thus hold, that the entire amount of those deposits is income to
Ms. Ng.
To summarize, except for the amounts that we found are not
income to Ms. Ng, we find, and thus hold, that all of the tip
account deposits are income to Ms. Ng.
Other Accounts
The revenue agent used unexplained cash deposits to other bank
accounts Ms. Ng owned or controlled as the basis to reconstruct Ms.
Ng's income.
Ms. Ng's personal checking account in the United States was at
the Bank of America in San Francisco. The deposits to the Bank of
America account, after reduction for reported and nontaxable rents
and partnership draws, determined to be unreported income,
included:
Number of Rent, Draw Unreported Income
Year Cash Deposits Deposits Reduction Adjustment
1986 $ 68,866 58 ($14,017) $ 54,849
1987 80,798 30 ( 30,354) 50,444
1988 121,760 56 ( 34,925) 1101,911
1989 61,210 37 -0- 61,210
1 No explanation was given for the mathematical discrepancy.
Ms. Ng controlled an account at Union Bank in San Francisco
that she opened in the name of Strong Hope, as well as an account
at Bank of the Orient in San Francisco in the name of Permanent
Union Ltd. Both companies were wholly owned by Ms. Ng. The
revenue agent analyzed the deposits to these accounts and
determined that the following unexplained cash deposits made to
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