- 2 - MEMORANDUM FINDINGS OF FACT AND OPINION FAY, Judge: These consolidated cases involve the following determinations by respondent of deficiencies in, and penalties on petitioners' Federal income taxes: Docket Nos. 10511-94, 19177-94, 3857-95 Chen C. & Victoria R. Wang Penalty Sec. Year Deficiency 6662(a) 1989 $76,529 $15,306 1990 398,475 79,695 1991 7,309 1,461 Docket Nos. 10512-94, 19176-94, 3858-95 EIC Group, Inc. and Subsidiaries Penalty Sec. Year Deficiency 6662(a) 1989 $5,469,221 $1,093,844 1990 1,919,053 383,811 1991 977,776 195,555 1992 1,171,312 234,262 All section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated. These cases were consolidated for trial, briefing, and opinion. Prior to trial, the parties settled a number ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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