-2-
Additions to Tax
Sec. Sec. Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(a)(1)(A) 6653(a)(1) 6653(a)(1)(B) 6654 6661 6662
1986 $1,327,802 $331,951 $66,390 --- 1 --- $331,951 ---
1987 830,395 207,850 41,570 --- 1 --- 207,850 ---
1988 878,617 219,654 --- $43,930 --- --- 219,654 ---
1989 1,431,742 357,936 --- --- --- --- --- $286,348
1990 256,186 64,047 --- --- --- $16,869 --- ---
1 50 percent of the interest on the portion of the underpayment attributable to negligence.
A substantial portion of the deficiencies and additions to tax was
asserted in respondent's amended answer.
In docket No. 21277-93, petitioner Strong Hope, Ltd. (Strong
Hope), a Hong Kong corporation wholly owned by Ms. Ng, seeks a
redetermination of the following deficiency and additions to tax:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6662
1989 $262,298 $52,460 $52,460
The aforementioned docketed cases have been consolidated for
trial, briefing, and opinion.
Following concessions by the parties, the issues remaining for
decision are: (1) Whether Ms. Ng had unreported income in the
amounts determined by respondent; (2) whether Ms. Ng is entitled to
claimed pass-through losses from her S corporation, Hong Kong
Restaurant, Inc.; (3) whether Ms. Ng is entitled to defer the gain
from the sale of certain real estate pursuant to section 1031; (4)
whether Ms. Ng received a liquidating distribution from Strong Hope
when that corporation transferred its interest in real estate to
her; (5) whether Ms. Ng is entitled to the entire investment
interest deduction claimed; (6) whether Ms. Ng is entitled to a
claimed net operating loss carryover; (7) whether Ms. Ng is liable
for an accuracy-related penalty and for additions to tax for
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