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All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
The issues for decision are:
(1) Whether petitioners failed to report income during the
1990 and 1991 taxable years. We hold that they did.
(2) Whether petitioners are liable for the accuracy-related
penalty under section 6662(a) for the 1990 taxable year. We hold
that they are.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation and the attached exhibits are incorporated herein
by this reference. Petitioners resided at 616 Winthrop Road, San
Marino, California, at the time their petition was filed. On
January 18, 1994, respondent issued a statutory notice of
deficiency to petitioners with respect to their 1990 and 1991
taxable years.
Petitioners have been married since 1982. Dennis J. Tang
(petitioner) was born in China.1 Petitioners first came to the
United States to reside in 1987. Petitioner's passport, issued
by the Republic of China, is in the name of Jung-Jing Tang.
1The record does not reveal where petitioner wife was born.
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