Big Hong Ng - Page 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,                  
          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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