Don A. Chan and Cecilia Chan - Page 12

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            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.                                                        




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