Big Hong Ng - Page 17

               Deposits into one of Ms. Ng's accounts at Wing Lung Bank were          
          as follows:                                                                 
                         Year           Total Deposits                                
                         1986           $260,442                                      
                         1987           1,558                                         
                         1988           11,141                                        
                         1989           167,515                                       
                         1990           34,754                                        
               Wire transfers from Wing Lung Bank and Hang Seng Bank into Ms.         
          Ng's Bank of America account in San Francisco were as follows:              
                         Year           Total Deposits                                
                         1986           $163,300                                      
                         1987           291,980                                       
                         1988           168,549                                       
                         1989           296,895                                       
          The revenue agent reduced the above amounts by $225,000 to account          
          for several nontaxable transactions that could be traced.                   
               Ms. Ng contends that partnership draws in cash from the Golden         
          Dragon Restaurant were improperly added to Ms. Ng's income by the           
          revenue agent.  In her bank deposits analysis, the revenue agent            
          subtracted substantiated partnership draws paid directly to Ms. Ng          
          from Golden Dragon Restaurant for 1987.  The revenue agent                  
          requested documents that would substantiate draws from the                  
          restaurant for other years, but Ms. Ng did not provide them.  Under         
          the circumstances, we find that it was appropriate for the revenue          
          agent to subtract from her calculation of Ms. Ng's unreported               
          income only those partnership draws that were substantiated.                
               Ms. Ng also contends that the revenue agent improperly treated         
          as income to Ms. Ng amounts that were deposited into accounts               

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