MEMORANDUM FINDINGS OF FACT AND OPINION
HOLMES, Judge:
Yung Chong gave money to his brother to help open a business in Beijing. He had another business in this country, and he and his wife, Anita, claimed large deductions on their 1998 tax return for losses from both. The Commissioner disallowed almost all of them due to a near complete lack of records. The Chongs blame this in part on a catastrophe suffered when a labor dispute at the Chong brothers' store...
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