Big Hong Ng - Page 22

          Investments, Limited to pay for Hong Kong Restaurant, Inc.  The             
          evidence does not support this claim.                                       
               To summarize, Ms. Ng proved an initial basis of $36,750 in the         
          stock of Hong Kong Restaurant, Inc. which was totally absorbed by           
          pass-through losses she claimed prior to 1986.  She did not prove           
          any additional contributions to capital or shareholder loans.               
          Accordingly, we hold that the deductions claimed during the years           
          under consideration were properly disallowed.                               
          Issue 3.  Section 1031 Exchange                                             
               Ms. Ng deferred gain from the sale of her Larkin and Lombard           
          Street properties in San Francisco pursuant to section 1031.  The           
          deferred gain from the sale of her Larkin Street property in 1988           
          was $393,177, and the deferred gain from the sale of her Lombard            
          Street property in 1989 was $516,633.  Ms. Ng's sale of her Larkin          
          and Lombard Street properties was followed by Strong Hope's                 
          conveyance of its one-half interest in an apartment building at 850         
          Stockton Street in San Francisco to Ms. Ng.  Ms. Ng owned the other         
          half interest in the Stockton Street property.  Respondent                  
          determined that Ms. Ng was not entitled to the deferred gain on the         
          sale of these 2 properties on the ground that Ms. Ng did not intend         
          to exchange the properties for like-kind property, as required to           
          obtain deferral of gain under section 1031.  The underlying facts           
          support respondent's assertions.                                            
               In July of 1988, Wing Lung Bank demanded that Ms. Ng satisfy           
          her delinquent bank loans.  Ms. Ng advised the bank that she would          

Page:  Previous  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  29  30  31  Next

Last modified: May 25, 2011