-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
Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 NextLast modified: May 25, 2011