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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 of
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