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Cheng C. and Susan L. Kao, docket No. 2982-94
Additions to Tax Penalty
Year Deficiency Sec. 6653(a)(1) Sec. 6661 Sec. 6662(a)
1988 $186,609 $9,330 $46,652 --
1989 975,338 -- -- $195,068
1990 663,670 -- -- 132,734
1991 347,457 -- -- 69,491
Kolyn Enterprises Corp., docket No. 2983-94
Additions to Tax Penalty
Year Deficiency Sec. 6653(a)(1) Sec. 6661 Sec. 6662(a)
1988 $ 182,456 $9,123 $45,614 --
1989 1,125,870 -- -- $225,174
1990 733,023 -- -- 146,605
1991 266,566 -- -- 53,313
KCW Associates Inc., docket No. 6667-95
Penalty
Year Deficiency Sec. 6662(a)
1990 $97,350 $19,470
1991 1,962 392
All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure. All dollar amounts
are rounded to the nearest dollar. After concessions, the issues
for decision are as follows:
1. Whether petitioners failed to report income. We hold
that they did to the extent provided below.
2. Whether petitioners are liable for additions to tax and
accuracy-related penalties. We hold that they are.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. At
the time the petitions were filed, Cheng and Susan Kao resided,
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