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The issues for decision are: (1) Whether the amounts
deposited into petitioners’ bank accounts are income or
nontaxable gifts; (2) whether respondent counted certain deposits
twice when determining petitioners’ deficiencies; (3) whether
petitioners are liable for the self-employment tax under section
1401;1 and (4) whether petitioners are liable for accuracy-
related penalties pursuant to section 6662(a).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the accompanying exhibits are
incorporated herein by this reference. Petitioners, Mr. Yang and
Mrs. Yang, are husband and wife and resided in Bellevue,
Washington, at the time they filed their petition.
Mr. Yang was born in Taiwan and became a U.S. citizen in
1985. Mr. Yang worked as a programmer/analyst for Mattel
Electronic in Los Angeles, California, from 1976 to 1982, a
system programmer for First Interstate Bank of California from
1982 to 1987, and a programmer specialist for Hughes Aircraft in
Los Angeles from 1987 to 1992. Mr. Yang also periodically
provided programming consulting services. Mrs. Yang has been a
homemaker since 1986. Mr. Yang owns a 3- to 4-percent interest
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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