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Petitioners paid interest on the loan from Jae Gilpin (Gilpin).
Petitioners were required to pay interest on at least a portion
of the loan from Su Chon Han.
Petitioners also incurred debt related to their purchase of
several automobiles during the years in issue.
Petitioners had the following personal credit card account
balances:
Date Credit Card Balance
Dec. 31, 1989 $20,521.99
Dec. 31, 1990 16,413.37
Dec. 31, 1991 26,075.24
JKY had the following nontaxable receipts during 1991:
Description Amount
Loan from Sunwest 1$40,000
Loan from shareholder 189,530
Loans from suppliers:
Price Mart 5,000
Almar Sales 14,000
La Coqurto 3,000
Total $151,530
1Respondent allowed these amounts in the notice of
deficiency.
JKY had $140,614.37 of sales returns/chargebacks during 1991.
Income Tax Returns
Patrick Caufield (Caufield) prepared petitioners' 1989
Form 1040, U.S. Individual Income Tax Return, and JKY's 1990
Form 1120S, U.S. Income Tax Return for an S Corporation. Caufield
did not review the tax returns with Yoon because of the
difficulty in communicating with him. Thomas Hwang prepared
petitioners' 1990 and 1991 Forms 1040 and JKY's 1991 Form 1120S.
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