- 2 -
all Rule references are to the Tax Court Rules of Practice and
Procedure.
In separate notices of deficiency, respondent determined
that petitioners are liable for the following deficiencies in
Federal income taxes:
Docket No. 10272-99S Eng Guek Kang
Taxable Year Deficiency
1995 $3,148
1996 2,443
1997 1,709
Docket No. 10902-99S Kok H. Ngo
Taxable Year Deficiency
1995 $10,084
1996 19,597
1997 13,911
After concessions by the parties,1 the issues for decision
1 The items and amounts listed below represent cost of
goods sold and deductions disallowed by respondent that were not
addressed by Mr. Ngo at trial. As a result, Mr. Ngo is deemed to
have conceded these items. See Rules 142(a), 149; Pearson v.
Commissioner, T.C. Memo. 2000-160.
Amount
1995 1996 1997
Cost of Goods Sold $1,652 $253 $9,566
Claimed Deduction Amount
1995 1996 1997
Car and truck $3,120 --- $1,893
Advertising 108 --- 160
Commission --- $30 ---
Office expenses 43 --- —--
Travel/meals/entertainment 10 --- —--
Other expenses 1,664 --- 270
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