Tan Dang and Ke T. Chaw Dang - Page 2




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             The issues for decision are:                                             
             1.  Whether petitioners correctly reported gross receipts                
        from their grocery store business for 1995, 1996, and 1997.  We               
        hold that they did.                                                           
             2.  Whether petitioners are liable for the accuracy-related              
        penalty for negligence for 1995, 1996, and 1997.  We hold that                
        they are not.                                                                 
             Section references are to the Internal Revenue Code in effect            
        for the years in issue.  References to petitioner are to Tan Dang.            
                                 FINDINGS OF FACT                                     
             Some of the facts are stipulated and are so found.                       
        A.   Petitioners                                                              
             Petitioners are husband and wife who resided in California               
        when they filed the petition.                                                 
        B.   Manwah Supermarket                                                       
             During the years in issue, petitioners owned and operated a              
        4,000-square-foot grocery store in downtown Los Angeles,                      
        California, known as L.A. Manwah Supermarket (Manwah).  Manwah was            
        a sole proprietorship in 1995 and a partnership in 1996 and 1997.             
             Petitioners sold meat, poultry, fruits, vegetables, canned               
        goods, and dry goods at Manwah.  Canned and dry goods were about              
        25 percent of Manwah’s sales, and meat, poultry, and produce were             
        about 75 percent.  Typically, the work at Manwah was performed by             








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