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the constructive dividends, (4) whether individual petitioners
are liable for an accuracy-related penalty under section 6662 for
1989, (5) whether corporate petitioner is liable for an addition
to tax under section 6653(a)(1)(A) and (B) for taxable year
ending March 31, 1988, (6) whether corporate petitioner is liable
for an addition to tax under section 6661 for taxable year ending
March 31, 1988, and (7) whether individual petitioners are liable
for additions to tax under sections 6653 and 6661 for 1987 and
1988 for their failure to report interest income from an overseas
bank account.
FINDINGS OF FACT3
At the time the petitions were filed, petitioners Don A. and
Cecilia Chan (individual petitioners) resided in San Francisco,
California, and petitioner Eastimpex (corporate petitioner), a
California corporation, had its principal place of business in
San Francisco, California. Individual petitioners are married.
Individual petitioners own 100 percent of the stock in
corporate petitioner. They began Eastimpex in 1971 and
incorporated Eastimpex in 1977. Eastimpex imports oriental food
and other goods from Taiwan and elsewhere for sale in the United
States. It began as the sales representative of Shin I Food
Factory Ltd. (Shin), a Taiwanese oriental food manufacturing
company started by petitioner husband's father, Henry S.T. Chan
3 The parties' stipulation of facts, along with the attached
exhibits, is incorporated herein by this reference.
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