-25-
property.
* 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
$309,056.94.
* 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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