Kin Sang Chan - Page 20




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          the “Asia Financial Crisis”, which according to him started on              
          October 23, 1997, at much higher prices and paid the tax due is             
          irrelevant to our consideration.5                                           
               Consequently, respondent’s refusal to further abate                    
          interest was not an abuse of discretion.  We have considered                
          all other arguments advanced by petitioner, and to the extent               
          not discussed above, have found those arguments to be                       
          irrelevant or without merit.                                                
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             for respondent.                          

















               5  We note that petitioner agreed to the tax deficiencies              
          and penalties for his 1992 and 1993 tax years in August of 1997,            
          before the start of the financial crisis in Asia, which                     
          petitioner alleges caused him to pay his tax liabilities in                 
          installments.  Petitioner chose to continue to speculate in the             
          Hong Kong Stock Exchange until he received his final statements             
          of account and bills for those tax years.                                   





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