Sam Kong Fashions, Inc. - Page 8

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               Similarly, in 1995, 18 checks issued by Style Setter,                  
          totaling $212,388.40, were deposited into Mr. Kong’s personal               
          checking account at Mellon Bank.  One of these checks issued by             
          Style Setters was payable to “Sam Kong Inc.”                                
               In 1994, Mr. Wen endorsed several of the checks that Style             
          Setter issued payable to either Sam Kong or Sam Kong Fashions.              
          Mr. Wen deposited seven checks, totaling $100,329.95, into an               
          account maintained at Corestates Bank.  Mr. Kong and Mr. Wen had            
          access to this account.                                                     
               During the taxable years 1994 and 1995, the accounting firm            
          of Kim Y. Ling, P.C., provided services to Sam Kong Fashions and            
          Mr. Kong.  Kim Y. Ling, P.C., prepared Sam Kong Fashions’s 1994             
          and 1995 tax returns.  Kim Y. Ling, P.C., also prepared Sam Kong            
          Fashions’s payroll checks, quarterly employer tax returns, and              
          Forms W-2, Wage and Tax Statement.  Kim Ling advised Mr. Kong to            
          report all income and to deposit all gross receipts into the                
          corporation’s bank account.  Mr. Kong did not inform Mr. Ling               
          that corporate checks had been either cashed or deposited into              
          noncorporate bank accounts until after respondent began his                 
          investigation of Mr. Kong and Sam Kong Fashions.                            
               During the taxable years 1994 and 1995, Sam Kong Fashions              
          reported gross receipts and deductions on its Forms 1120, U.S.              
          Corporation Income Tax Return, as follows:                                  







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Last modified: May 25, 2011