-19- unreported income in the amounts determined by respondent. A final note with respect to the unreported income issue. In her posttrial brief, Ms. Ng asserts that "the nature of this case cries out for a net worth analysis" and requests the Court to "direct the parties to cooperate in an effort to do a net worth analysis to reach a more accurate and just result." We will not accede to Ms. Ng's request. Whatever Ms. Ng's net worth, it is not relevant to whether the bank deposits and other income traced to her during the years under consideration constitute income to her. What happened to this income after Ms. Ng received it does not change its character as income. Moreover, there is "no requirement that the Commissioner use the net worth method for computing income." Estate of Mason v. Commissioner, 64 T.C. at 662. Issue 2. Hong Kong Restaurant Losses We now turn our attention to whether Ms. Ng is entitled to claimed pass-through losses from her solely owned S corporation, Hong Kong Restaurant, Inc. This, in turn, depends upon whether Ms. Ng had sufficient basis in that corporation to claim the losses. Pursuant to section 1366, S corporation income, losses, deductions, and credits are passed through pro rata to shareholders. The amount that can be claimed is limited to the sum of a shareholder's adjusted basis in the corporate stock, and his 1(...continued) Bank account are the income of Ms. Ng.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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