- 4 - that Kolyn received $790,000. The disclosures stated that these funds were not taxable to either Kolyn or the Kaos. In 1992, the Internal Revenue Service conducted an audit of Kolyn's 1988, 1989, and 1990 returns. Agent Jimmy Chan was assigned to the case. On January 14, 1992, Agent Chan met with Dr. Kao for approximately 7 hours to review Kolyn's corporate records. During the interview, Agent Chan discovered numerous deposits in Kolyn's accounts. In response to Agent Chan's questions, Dr. Kao explained that these deposits were cash gifts from his father. Dr. Kao refused, however, to provide Agent Chan with any records to corroborate his explanation. Because Dr. Kao failed to provide records to corroborate his explanation for these and other deposits in petitioners' accounts, respondent used the bank deposits method to reconstruct petitioners' income for the years in issue. After completing this analysis, respondent issued notices of deficiency to petitioners and determined for the years in issue that: (1) KCW received unreported income of $121,857; (2) the Kaos received unreported income of $905,502; and (3) Kolyn received unreported income of $6,777,319, and this amount was taxable to both Kolyn and the Kaos. Respondent has subsequently conceded that a $300,000 deposit into Cheng and Susan Kao's checking account, as well as funds deposited into two other accounts at World Savings and Loan, are not taxable to the Kaos. OPINIONPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011