Michael and Kazuko Yang - Page 10




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          including inconsistencies in their testimony, we do not find Mr.            
          Yang or Fang Long Yang to be credible with respect to this issue.           
               Petitioners’ explanation for the bank deposits is that all             
          of the money deposited was the proceeds of gifts.  Petitioners              
          testified that neither of them was gainfully employed or engaged            
          in business after Mr. Yang discontinued his employment at Hughes            
          Aircraft.                                                                   
               However, in their loan applications, signed under penalty of           
          perjury, petitioners told a different story.  They reported                 
          earning substantial amounts of business income, and Mr. Yang was            
          classified as self-employed.  The Bank of Taiwan account was                
          referred to as a “business account”,7 Mr. Yang admitted spending            
          an increasing amount of time overseas for work, and he stated               
          that he had manufacturing clients in Taiwan.  Petitioners claim             
          that they misrepresented their financial information on the loan            
          applications in order to get the loans approved and inadvertently           
          failed to disclose the Bank of Taiwan account on their income tax           
          returns.  Based on the contradictory evidence, we do not find               
          petitioners’ explanations to be persuasive.  Accordingly, with              
          the exceptions noted below, we hold that the amounts deposited              
          into petitioners’ bank accounts in 1995 and 1996 are taxable                
          income.                                                                     


               7Petitioners failed to report their interest in the Bank of            
          Taiwan account on their 1995 and 1996 tax returns.                          





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