Chong-Kak and Sang-Ok Lee - Page 28

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          called several witnesses to try to explain Hamalee's separate               
          books, the witnesses' implausible and inconsistent explanations             
          leave us with the firm belief that the sole reason for the dual             
          books was to hide income from the Government.12  To restate what            
          was stated by the Court of Appeals for the Second Circuit in a              
          setting of fraud, "We look at the record as a whole which has a             
          constant drum beat of fraud to which our ears are not deaf."                
          Geller v. Commissioner, 556 F.2d 687, 691 (1977), affg. T.C.                
          Memo. 1976-257.                                                             
               For the foregoing reasons, we hold that:  (1) Hamalee is               
          liable for the additions to its 1985 and 1986 taxes determined by           
          respondent under section 6653(b)(1) and section 6653(b)(1)(A),              
          respectively, and (2) the Lees are liable for the additions to              
          their 1987 and 1988 taxes determined by respondent under section            
          6653(b)(1)(A) and section 6653(b)(1), respectively.  In so                  
          holding, we have considered all arguments made by the parties               
          and, to the extent not addressed above, have found them to be               
          without merit.13                                                            

          12 Mrs. Lee, for example, gave at least five different                      
          answers to the question of why Hamalee had two sets of books, and           
          why its tax preparers were only given one of those sets.                    
          13 In particular, petitioners cite Kiyono v. Commissioner, a                

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