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raise the cash needed to pay off her loans by selling the Larkin
Street and Lombard Street properties in an exchange transaction.
Ms. Ng entered into a contract to sell the Larkin Street
property to David Mandel for $565,000 on September 2, 1988. She
subsequently transferred the property to Independent Exchange
Services, Inc. (IES), which in turn transferred the property to Mr.
Mandel on November 10, 1988. The net cash due Ms. Ng was
$85,317.57 after all existing loans and taxes were paid.
Ms. Ng entered into a contract to sell the Lombard Street
property to JSM & Inter Realty Corporation for $990,000 on January
5, 1989. She subsequently transferred the property to IES, which
in turn transferred the property to JSM & Inter Realty Corporation
on February 6, 1989. The net proceeds from this sale to Ms. Ng
($304,178.26) were placed in an escrow account with Founders Title
Company (Founders).
On January 11, 1989, Ms. Ng agreed to pay $1.1 million to
Strong Hope for the purchase of Strong Hope's 50-percent interest
in the Stockton Street property. Also on January 11, Ms. Ng and
Strong Hope agreed to an addendum to the sale contract providing
that IES would be substituted for Ms. Ng as buyer, and that once
Strong Hope conveyed the property to IES, the property then would
be transferred from IES to Ms. Ng.
Ms. Ng was required to pay $100,000 to the Internal Revenue
Service (IRS) on May 9, 1989, apparently to satisfy a tax lien, in
order to open her restaurant in San Francisco. She also had to
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