Shigenori Kudo and Motomi Kudo, et al. - Page 21

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          sport.  Yoshinori held the second highest kendo rank and was a              
          representative to the World Kendo Association in Japan.  Because            
          of Yoshinori's frequent travel, the Takaos gave Nakamura a power            
          of attorney to write checks on their behalf.  Nakamura had                  
          handled the Takaos' financial affairs and prepared their tax                
          returns since 1965.                                                         
               During the years in issue, the Takaos made bank deposits as            
          follows:                                                                    
          Year          Amount                                                        
          1988         $122,483                                                       
          1989           75,421                                                       
          1990          114,935                                                       
          1991          109,094                                                       

          Of the 1991 deposits, $48,194, $26,244, and $7,495 were deposited           
          into bank accounts in Japan.  The parties have stipulated that              
          those deposits were rents received from an apartment building the           
          Takaos owned in Tokyo, Japan.  Construction of the apartment                
          building was completed in 1991.  The parties have stipulated                
          further that only $10,108 of the Japanese bank deposits is                  
          taxable income, rather than the $81,933 determined in the notice            
          of deficiency.  The rental deposits in the Japanese banks were              
          not reported on the Takaos' 1991 return, because Nakamura                   
          believed that, since Japanese tax returns were filed, there was             
          no need to report the income on the U.S. returns because of the             
          foreign tax credit.                                                         






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