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(Chung Kim) and Ok Hui Kim (Ok Kim) resided in Hayward,
California.
Petitioners were married in Korea during 1970 and immigrated
to the United States in 1973. Petitioners have been U.S.
residents from that date through the years at issue.
Chung Kim, a high school graduate, worked in Korea in the
Korean movie industry and then as an artist in the United States.
Ok Kim, also a high school graduate, worked as a dance instructor
in Korea and then as a typist in the United States. In 1977,
petitioners opened a retail store of approximately 800 square
feet on O’Farrell Street in San Francisco, California.
In 1992, petitioners relocated their store to a 3,000-
square-foot retail space on Geary Boulevard in San Francisco.
During the years at issue, petitioners operated their store as a
sole proprietorship named Top Blue Jeans/TBJ Collection (TBJ) and
sold merchandise at retail including clothing, cosmetics,
jewelry, leather goods, and other items of personal property.
Petitioners filed joint 1993, 1994, and 1995 Federal income
tax returns (Form 1040). The only source of taxable income
reported on those returns was gross receipts from TBJ of
$698,632, $846,030, and $1,032,759, respectively. Petitioners
initially reported costs of goods sold for the respective years
of $506,960, $625,553, and $765,298. The parties stipulated that
petitioners’ costs of goods sold were $859,563, $973,460, and
$866,771, respectively.
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