Tae M. Kim and Young J. Kim - Page 2




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               Respondent determined deficiencies in petitioners' Federal             
          income taxes for 1993 and 1994 in the amounts of $4,972 and                 
          $5,465, respectively, and accuracy-related penalties pursuant to            
          section 6662(a) in the amounts of $873 and $1,093, respectively.            
               The issues for decision are:  (1) Whether petitioners are              
          entitled to trade or business expense deductions for 1993 and               
          1994 in excess of the amounts allowed and conceded by respondent;           
          (2) whether petitioners are entitled to a medical expense                   
          deduction for 1993 in excess of the amounts allowed and conceded            
          by respondent; and (3) whether petitioners are liable for the               
          section 6662(a) accuracy-related penalties for 1993 and 1994.               
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact and the attached exhibits are                      
          incorporated herein by this reference.  Petitioners resided in              
          Bowie, Maryland, on the date the petition was filed in this case.           
          All references to petitioner in the singular are to Tae M. Kim.             
               Petitioner is licensed to practice professional engineering            
          by the State of Maryland, Department of Licensing and Regulation,           
          Board for Professional Engineers.  During 1993 and 1994,                    
          petitioner operated an engineering business under the business              
          name of Advance Design Engineering (ADE).  He kept an office in             
          petitioners' condominium unit for which respondent has allowed              


          1(...continued)                                                             
          issue.  All Rule references are to the Tax Court Rules of                   
          Practice and Procedure.                                                     




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