Joanne Soon Kim - Page 2

                  Some of the issues raised by the pleadings have been                                    
            disposed of by agreement of the parties, leaving for decision                                 
            whether a valid Consent to Extend the Time to Assess Tax (Form                                
            872) for the year 1989 was executed by or properly on behalf of                               
            petitioner.2                                                                                  
                                           FINDINGS OF FACT                                               
                  Some of the facts have been stipulated and are found                                    
            accordingly.                                                                                  
                  Petitioner had a legal residence in Seal Beach, California,                             
            at the time of the filing of her petition in this case.  She                                  
            filed a joint Federal income tax return with her then husband,                                
            Charles K. Kim (Mr. Kim), for the taxable year 1989.                                          
                  Petitioner is known both as Joanne Kim and Soon Kim.  During                            
            1989, petitioner owned and operated two cafeterias, each called                               
            "Joanne's Cafe".  One cafeteria was located in Irvine,                                        
            California, and the other in Long Beach, California.  Petitioner                              
            opened the cafeteria in Long Beach in 1985 and the cafeteria in                               
            Irvine in 1987.  Petitioner was actively involved in the                                      
            operation of each of these cafeterias.                                                        
                  On or about March 26, 1991, respondent began the audit of                               
            petitioner's 1989 Federal income tax return.  Shortly after the                               
            commencement of the audit, petitioner and her husband were                                    
            divorced.  Mr. Kim did not reside with petitioner at 640 Taper                                




            2  Petitioner conceded at trial the correctness of                                            
            respondent's adjustments to her return and her lack of                                        
            entitlement to relief under sec. 6013(e) as an innocent spouse.                               


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