3-KOAM Company, A Partnership, My Hat, Inc., Tax Matters Partner - Page 5

                                        - 5 -                                         
          a 0 percent interest promissory note to Dooyong for $82,000.  The           
          maturity date of the note was March 17, 1993.                               
               On March 29, 1991, Dooyong shipped two video games4 to                 
          3-Koam.  For U.S. Customs' purposes, Dooyong declared $4,500 as             
          the total value of the games.  This was the only import                     
          transaction between Dooyong and 3-Koam.  Thereafter, 3-Koam test            
          marketed its product by placing one of the games in an arcade in            
          Santa Clara, California, and the other in Santa Cruz.  After 4              
          weeks, 3-Koam determined that the games did not attract                     
          sufficient customers and had no residual value, and therefore               
          decided to abandon the idea of distributing arcade video games.             
          3-Koam never attempted to sell the games to any other person or             
          entity.                                                                     
               Neither Inkax nor 3-Koam ever paid Dooyong for its                     
          development efforts.  Moreover, at the time of trial, Inkax had             
          closed its bank account and dissolved.  Dooyong has never taken             
          any legal recourse against 3-Koam or Inkax to enforce the $82,000           
          promissory note issued by Inkax.                                            
               On its 1990 U.S. Partnership Return of Income (Form 1065),             
          the only transactions Inkax reported were the accrual of $90,000            
          of income from 3-Koam, and an accrual of $82,000 as cost of goods           
          sold, reflecting the promissory note issued to Dooyong, which               
          produced an $8,000 operating profit.  Houston and Paik each                 

          4    Dooyong actually shipped 3-Koam video game circuit boards,             
          which 3-Koam then assembled into two video game arcade cabinets.            




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  Next

Last modified: May 25, 2011