Kin Sang Chan - Page 7




                                        - 7 -                                         
          Offer to Waive Restrictions on Assessment and Collection of Tax             
          Deficiency and to Accept Overassessment, enclosed with the July             
          29 letter, KSCI was treated as an S corporation.  The Form 870-AD           
          reflected adjustments to increase the taxable income of KSCI by             
          $48,864 and $49,092 for 1992 and 1993, respectively.  Because               
          KSCI was treated as an S corporation, there was no tax imposed on           
          KSCI as a result of the adjustments.                                        
               The Form 870-AD reflected adjustments to increase the                  
          taxable income of petitioner and his wife by $42,755 and $42,803            
          for 1992 and 1993, respectively.  As a result of the increases in           
          taxable income, the Form 870-AD set forth increases in the Chans’           
          tax liabilities of $9,477 and $9,868 for the respective tax                 
          years.  On August 4, 1997, Mr. and Mrs. Chan executed the Form              
          870-AD.                                                                     
               On August 21, 1997, Mr. Peter sent a letter to petitioner              
          reciting approval of the settlement of examination changes.  In             
          the Appeals Transmittal and Supporting statement, dated August              
          21, 1997, Mr. Peter explained that it was an error for the                  
          examining agent to treat KSCI as a C corporation in the                     
          examination.  Mr. Peter concluded that KSCI was not a personal              
          holding company, and that absent evidence to the contrary,                  
          petitioner would not be treated as having received constructive             
          dividends from KSCI in 1992 and 1993.                                       








Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011