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negligence, substantial understatement, failure to file timely
returns, and failure to pay estimated tax; (8) whether Strong Hope
had discharge of indebtedness income; (9) whether Strong Hope's
basis in certain real estate that it transferred should be adjusted
as determined by respondent; (10) whether respondent properly
disallowed a net operating loss carryover to Strong Hope; and (11)
whether Strong Hope is liable for an accuracy-related penalty and
for an addition to tax for failure to file a timely return.
All section references are to the Internal Revenue Code for
the years under consideration. All Rule references are to the Tax
Court Rules of Practice and Procedure.
Some of the facts have been stipulated and are so found. The
stipulations of facts and the attached exhibits are incorporated
herein by this reference.
Background
Ms. Ng, also known as Don Hong Ng, Bik Hung Ng Leong, and
other names, resided in San Francisco, California, at the time she
filed her petition. Ms. Ng's tax returns for all years under
consideration were untimely filed.
Ms. Ng was born in 1935 and came to the United States from
Hong Kong in approximately 1958. She studied English and music in
the United States, and became a resident alien shortly after her
marriage in 1962 to Sik Chong Leong in Reno, Nevada. They were
divorced in 1968 and had no children. Ms. Ng acquired her U.S.
citizenship in 1966. Ms. Ng has a son, Timothy Lee, who was born
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