Srichai and Pusadee Rungrangsi - Page 2

                                        - 2 -                                         

               1993        22,226          1,514          4,445                       
               1994        19,178            673          3,836                       
               All section references are to the Internal Revenue Code for            
          the years in issue.  All Rule references are to the Tax Court Rules         
          of Practice and Procedure.                                                  
               The deficiencies herein generally relate to petitioners'               
          ownership and operation of a restaurant in Stanton, California.             
          The issues for decision are: (1) Whether a purported sale of a              
          restaurant (Stanton Mexicatessen) from petitioners to Suvanee               
          Eagatatt on September 15, 1993, should be recognized for tax                
          purposes, so that petitioners would be entitled to a capital loss           
          on the sale for that year; (2) whether petitioners properly                 
          reported the income from the operation of Stanton Mexicatessen  for         
          1992, 1993, and/or 1994; (3) whether petitioners are entitled to            
          deductions for investment interest expenses for 1992, 1993, and/or          
          1994; (4) whether petitioners are liable for additions to tax               
          pursuant to section 6651(a) for failure to timely file their tax            
          returns for 1992, 1993, and 1994; and (5) whether petitioners are           
          liable for accuracy-related penalties pursuant to section 6662 for          
          1992, 1993, and 1994.                                                       
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.  The          
          stipulated facts are incorporated in our findings by this                   
          reference.                                                                  






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011