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and Kolyn Enterprises Corp. and KCW Associates, Inc., each had
their principal place of business, in Los Altos, California.
Petitioners Cheng and Susan Kao were born and raised in
Taiwan. In 1964, Cheng Kao moved to the United States to pursue
graduate studies in applied physics at Harvard University. In
1969, he received a Ph.D. In 1968, Susan Kao moved to the United
States to pursue graduate studies in chemistry at the University
of Rochester. She married Dr. Kao in 1970, and they have three
children. During the years in issue, Mrs. Kao was employed as an
engineer at Intel Corp., and Dr. Kao was employed as president of
Kolyn Enterprises Corp. (Kolyn) and as vice president of KCW
Associates, Inc. (KCW). Dr. Kao has five younger siblings, four
of whom reside in the United States. His sister, Yu-Hsia Kao Tu,
resides in Taiwan.
Kolyn is a closely held corporation that trades in
electronic goods, invests in real estate, and advises Asian
electronics companies. Dr. and Mrs. Kao together own 52 percent,
and their three children each own 16 percent, of Kolyn's stock.
KCW is a closely held corporation that trades in electronic goods
and invests in real estate. KCW's stock is held by Dr. Kao and
his relatives.
During the years in issue, petitioners filed their Federal
income tax returns in a timely manner. Kolyn's returns, on
Schedule L, reported increases in long-term liabilities. On
their 1991 returns, the Kaos and Kolyn disclosed, on Forms 8275,
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