Jung K. Yoon and Hee S. Yoon - Page 13

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          of the year.  Third-party records, petitioners' depreciation                
          schedules, and Department of Motor Vehicles' records were used to           
          calculate petitioners' ownership of personal property.                      
               Respondent computed petitioners' increase in the ownership             
          of real property by determining the real property owned at the              
          end of the year less what was owned at the beginning of the year.           
          Respondent obtained the records relating to petitioners'                    
          acquisition of real property from third-party sources.                      
          Respondent used amortization tables to calculate loan balances at           
          the end of each taxable year.                                               
               All payments from petitioners' personal bank accounts on               
          credit card account balances were treated as personal living                
          expenses in respondent's computation of petitioners' net worth.             
               Respondent determined petitioners' February 1, 1990,                   
          investment in JKY by netting assets and liabilities transferred             
          to JKY as follows:                                                          



















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