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          that respondent's computation of the assets and depreciation                
          transferred to JKY was in error.                                            
               Finally, petitioners argue that JKY assumed certain payroll            
          taxes that should reduce petitioners' capital account balance for           
          each of the years in issue.  Caufield testified that JKY assumed            
          various payroll tax liabilities as part of the section 351                  
          transfer.  These payroll taxes were included on Caufield's "S               
          Corporation 351 Transfer".  Respondent determined that JKY did              
          not assume these liabilities.  By Caufield's own admission at               
          trial, the "S Corporation 351 Transfer" represented his initial             
          computation.  Petitioners have not provided any evidence, through           
          Yoon's testimony or canceled checks, of JKY's assumption or                 
          payment of these payroll tax liabilities.  Respondent's                     
          determination that JKY did not assume various payroll tax                   
          liabilities will be sustained.                                              
               3.  Personal Living Expenses                                           
               Petitioners argue that their personal living expenses for              
          1989 were less than those calculated by respondent.  Petitioners            
          claim that certain expenditures, mainly life insurance payments             
          and income tax payments, were incurred in 1990 and not in 1989.             
          This, petitioners claim, would make a difference because                    
          respondent used a discounted 1990 figure to determine                       
          petitioners' 1989 personal living expenses.  If only the                    
          recurring items of expense were included for both years before              
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