Dennis J. Tang and Alice Shu-Ling Tang - Page 2

                                        - 2 -                                         
          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.                 




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  Next

Last modified: May 25, 2011