Don A. Chan and Cecilia Chan - Page 2

                                                 - 2 -                                                   
            an accuracy-related penalty on Federal income tax for individual                             
            petitioners Don and Cecilia Chan as follows:2                                                

                                                                          Accuracy                       
                                                                                -related                 
                               Additions to Tax                Penalty                                   
                              Sec.         Sec.        Sec.        Sec.    Sec.                          
            Year  Deficiency   6653(a)(1) 6653(a)(1)(A)  6653(a)(1)(B)   6661   6662(a)                  
            1987 $934,911     ---       $46,746                1       $61,350    ---                    
            1988  708,273   $35,414     ---        ---        30,992    ---                              
            1989   693,857        ---     ---            ---          ---   $14,667                      
                  1 50 percent of the interest due on the portion of the underpayment                    
            attributable to negligence.                                                                  
                  Respondent determined deficiencies in and additions to                                 
            Federal income tax for corporate petitioner Eastimpex for the                                
            taxable years ending March 31, 1988 and 1989, as follows:                                    
                                     Additions to Tax                                                    
                                           Sec.        Sec.        Sec.                                  
            Year     Deficiency    6653(a)(1)(A)    6653(a)(1)(B)    6661                                
            1988      $766,321       $38,316            1          $191,580                              
            1989       815,234      ---     ---     203,809                                              
                  1  50 percent of the interest due on the portion of the underpayment                   
            attributable to negligence.                                                                  
                                                                                                        
                  After concessions, the issues for decision are:  (1) Whether                           
            certain payments by corporate petitioner Eastimpex to its related                            
            supplier were costs of goods sold, (2) whether individual                                    
            petitioners realized constructive dividends from Eastimpex, (3)                              
            whether individual petitioners are liable for additions to tax                               
            under sections 6653 and 6661 for 1987 and 1988 attributable to                               


                  2 All section references are to the Internal Revenue Code in                           
            effect for the taxable years in issue, and all Rule references                               
            are to the Tax Court Rules of Practice and Procedure, unless                                 
            otherwise designated.                                                                        




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