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Shigenori Kudo and Motomi Kudo
(docket Nos. 10667-94 and 19180-94)
After concessions,2 the following issues remain in dispute:
(1) Whether petitioners Shigenori Kudo (Scott) and Motomi
Kudo (Motomi) (hereinafter collectively referred to as the Kudos)
received unreported income in the amounts of $55,979 and $57,795
for 1990 and 1991, respectively, as shown by unexplained bank
deposits made by them during those years. We hold that they
received unreported income in the amounts decided herein.
(2) Whether the Kudos are liable for accuracy-related
penalties for negligence under section 6662(a) for 1990 and 1991.
We hold that they are.
Yoshinori Takao and Estate of Akiko Takao, Deceased,
Yoshinori Takao, Successor-in-Interest
(docket Nos. 466-95 and 467-95)
2 The parties settled some of the adjustments determined in
the notices of deficiency dated Mar. 21, 1994, and July 19, 1994,
as follows:
1. The Kudos agree that the adjustments entitled "Rec'd
from Toraya Corp. & Rest." are correct to the extent of $25,230
in 1990 and $24,000 in 1991.
2. Respondent agrees that the Kudos are entitled to
additional Schedule A deductions for 1990 and 1991 in the amounts
of $21,249 and $17,634, respectively.
3. Respondent concedes the adjustment for 1991 entitled
"Taxes Paid by Employer" in the amount of $9,214.
4. The Kudos concede that the adjustment for "Taxes Paid by
Employer" for 1990 should be $6,942.
5. Respondent concedes that the adjustment entitled
"Unexplained Deposits" for 1990 in the amount of $55,979 should
be reduced to $42,506.
6. Respondent concedes that the adjustment entitled
"Unexplained Deposits" for 1991 in the amount of $57,795 should
be reduced to $53,011, by $652 representing an insurance payment
and $4,132 representing refunds of State and Federal taxes.
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