- 12 - individual petitioners' deficiency attributable to the interest income for 1987 and 1988 in the amounts of $15,731 and $19,722, respectively. Petitioner husband was aware of the Standard Chartered account and its balance. Statements from the Standard Chartered bank account were addressed to "Chan Don A. & Lily Chan". In prior years, the statements were usually mailed to Eastimpex's office. During the years in issue, however, the statements were mailed to an address in Hong Kong. Individual petitioners received mail regarding their personal finances at their personal address as well as at their Eastimpex office. They depended on Eastimpex's bookkeepers to turn over mail received at Eastimpex to petitioners' accountant. Individual petitioners did not file Treasury Form 90-22.1, Report of Foreign Bank and Financial Accounts, during the years in issue to disclose the overseas bank account, as required. OPINION Corporate petitioner Eastimpex has failed to produce invoices for a portion of the amount it claimed as the cost of goods sold. Eastimpex contends that it did not receive accurate invoices of its costs in order to help its related supplier Shin conceal income from the Taiwanese Government. Eastimpex asserts that this scheme was devised only to avoid Taiwanese tax and not to deceive the Internal Revenue Service in any way. We do not find this explanation to be credible.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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