Jung K. Yoon and Hee S. Yoon - Page 15

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          shareholder loans made during the year and income reported by               
          JKY, less distributions made during the year.                               
               Investment as of 12/31/90     $265,043.27                              
               Increased by:                                                          
                    1991 Income              165,003.00                               
                    Loans to JKY             89,530.00                                
               Decreased by:                                                          
                    1991 Distributions       (134,105.00)                             
               Investment as of 12/31/91     $385,471.27                              
          Income Pass-Through--Form 1120S Adjustment                                  
               Respondent based the proposed adjustments to JKY's 1990 and            
          1991 income on the bank deposit method.  Respondent conceded the            
          Form 1120S adjustment for taxable year 1990 in the amount of                
          $38,321 based upon information supplied by petitioners during the           
          preparation of this case for trial.                                         
                                       OPINION                                        
          Unreported Income                                                           
               The first issue for resolution is whether petitioners                  
          underreported their taxable income for each of the years in                 
          issue.  In this case, the evidence of unreported income consists            
          of respondent's net worth and bank deposit analyses.  The                   
          validity of those analyses must be examined by applying the                 
          standards set forth in Holland v. United States, 348 U.S. 121               
          (1954).  Under those standards, respondent must establish, with             
          reasonable certainty, an opening net worth; and she must                    
          establish that either a likely source of unreported income                  





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