- 3 - 4. Whether Hamalee had a net operating loss (NOL) in 1989, that the Lees may carry back to the subject years. We hold it did not.1 5. Whether petitioners are liable for the additions to tax for fraud determined by respondent. We hold they are to the extent stated herein. 6. Whether petitioners are liable for the additions to tax for substantial understatements determined by respondent. We hold they are. Unless otherwise stated, section references are to the Internal Revenue Code in effect for the years in issue. Rule references are to the Tax Court Rules of Practice and Procedure. We separately refer to Chong-Kak and Sang-Ok Lee as Mr. Lee and Mrs. Lee, respectively. We collectively refer to Mr. Lee and Mrs. Lee as the Lees. We refer to the Lees' daughter, Inae Lee, as Ms. Lee. We refer to the Lees' son-in-law, Ick Soo Won, as Mr. Won. We refer to Hamalee Distributors, Inc., as Hamalee. We refer to Myun Suk Chong as Ms. Chong. FINDINGS OF FACT 1 Our resolution of this issue moots another issue raised by the parties as to Mr. Lee's basis in his Hamalee stock on Dec. 31, 1989.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011