- 14 -
1982-603; Beddow v. Commissioner, supra.
Petitioners’ income was consistently underreported, and in
the aggregate petitioners failed to report over $2 million of
TBJ’s sales from 1993 through 1995. This is a substantial sum,
especially in light of the fact that petitioners reported
adjusted gross income for those 3 years in the amounts of only
$22,022, $38,357 and $46,388. Additionally, petitioners were
unable or unwilling to produce daily sales records for their
accountant, the IRS, or the Court. Neither petitioners’
accountant nor anyone else ever audited petitioners’ business,
and their accountant never reviewed any of TBJ’s daily cash
register tapes.10
Moreover, petitioners’ explanations of having received
substantial cash inheritances and loans from U.S. and Korean
relatives are highly implausible and wholly lacking in
credibility. Petitioners testified that they did not
fraudulently conceal TBJ’s sales proceeds from U.S. tax
authorities but instead colluded with their Korean relatives to
conceal the conversion and transfer of nearly 2 million dollars
worth of Korean currency from U.S. and Korean customs agents.
Yet petitioners could produce no single piece of documentary
evidence that their Korean relatives ever possessed these funds
10Petitioners’ accountant testified that Chung Kim reported
TBJ’s cash receipts to him orally.
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