Jung K. Yoon and Hee S. Yoon - Page 28

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          final product of the revenue agent, especially in light of her              
          failure to testify regarding this omission.  Respondent has                 
          failed to prove that she understated JKY's gross receipts for               
          1991 in making her determination.                                           
               At trial, Yoon also testified as to the existence of certain           
          liabilities to his suppliers resulting from cash advances                   
          received from the suppliers.  These liabilities, petitioners                
          claim, increase JKY's nontaxable receipts.  Respondent allowed              
          $129,530 of other nontaxable receipts.                                      
               Petitioners have presented Yoon's testimony and several                
          deposit slips with the names of JKY's Korean-owned suppliers                
          listed next to amounts of the checks deposited as evidence of               
          these debts.  Yoon testified that no notes were executed, that no           
          interest was charged, and that he could not recall when he repaid           
          the debts.  Yoon also testified that JKY had outstanding credit             
          balances with the companies that loaned him money.  At trial,               
          respondent questioned why the suppliers would have loaned JKY               
          cash instead of reducing the outstanding account balances.  Yoon            
          responded that there was a need for money at the time.  Because             
          JKY was a big customer of these suppliers and Yoon often                    
          entertained the suppliers to garner favor, it is not incredible             
          that suppliers would advance to JKY relatively small amounts of             
          cash (when compared to the purchases JKY was making from the                
          suppliers).  JKY's nontaxable receipts for 1991 should be                   






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