Richard Soo Kim and Donna Kim - Page 1

                                 T.C. Memo. 1995-598                                  

                               UNITED STATES TAX COURT                                

                    RICHARD SOO KIM AND DONNA KIM, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

     Docket No. 24243-93.    Filed December 19, 1995.                                 

     Richard Soo Kim and Donna Kim, pro se.                                           
     Brently W. Free, for respondent.                                                 

                                 MEMORANDUM OPINION                                   
          COHEN, Judge: Respondent determined a deficiency of $90,593                 
          in petitioner's Federal income tax for 1990 and an addition to              
          tax of $18,118.60 pursuant to section 6662(a). Unless otherwise             
          indicated, all section references are to the Internal Revenue               
          Code in effect for the year in issue, and all Rule references are           
          to the Tax Court Rules of Practice and Procedure.                           

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