Cheng C. and Susan L. Kao, et al. - Page 4

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            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.                                                    
                                              OPINION                                                 




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