Big Hong Ng - Page 25

               *    January 13, 1989--IES check deposited into Strong Hope's          
          Union Bank account, purportedly as a deposit toward the purchase            
          price of the Stockton Street property.  Ms. Ng purchased a money            
          order for $85,165.54 with funds from Strong Hope's Union Bank               
          account.  She used the money order to make a mortgage payment on            
          the Stockton Street property, one-half of which she owned outright.         
          One-half of the payment ($42,583.27)--benefiting the other 50-              
          percent interest in the Stockton Street property Strong Hope owned          
          --was recorded as a loan to Strong Hope from Ms. Ng.                        
               *    May 16,  1989--Founders issued check to IES for                   
               *    May 23, 1989--IES issued check to Strong Hope for                 
          $157,161.59, representing net proceeds after tax withholding from           
          sale of the Lombard Street property.  Of the $303,828.26 disbursed,         
          IES withheld $110,000 for the IRS and $36,666.67 for the California         
          Franchise Tax Board.                                                        
               *    May 25, 1989--IES check for $157,161.59 deposited into            
          Strong Hope's Union Bank account, where the balance was $1,469              
          immediately prior to the deposit.  Ms. Ng purchased 3 cashier's             
          checks on May 25 with the deposited funds:  $100,000 payable to             
          Strong Hope Limited, a California corporation (Strong Hope                  
          Limited), which is not the same entity as petitioner Strong Hope,           
          Ltd., a Hong Kong corporation and purported seller of the Stockton          
          Street property; $25,000 payable to Strong Hope Limited; and                

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Last modified: May 25, 2011