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are: (1) Whether petitioners are entitled to head of household
filing status on their respective individual Federal income tax
returns during the years at issue; (2) whether petitioner Eng
Geuk Kang (Ms. Kang) is entitled to earned income credits during
the years at issue; (3) whether petitioner Kok H. Ngo2 (Mr. Ngo)
is entitled to earned income credits during the years at issue;
(4) whether Mr. Ngo failed to report gross receipts of $7,275,
$21,421, and $5,409, respectively, during the years at issue, on
Schedules C, Profit or Loss From Business; and (5) whether Mr.
Ngo is entitled to deduct certain Schedule C expenses in excess
of amounts allowed by respondent for the years at issue.3 The
resolution of the first three issues turns on whether petitioners
were considered married pursuant to the provisions of section
7703(b).
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the
respective petitions were filed, petitioners resided in Auburn,
Washington.
2 Mr. Ngo is also known as Guo Xing Woo; however, for the
purpose of this opinion, we shall refer to him as Mr. Ngo.
3 Our resolution of the issues in this case at docket No.
10902-99S will also resolve respondent’s adjustment to the amount
of self-employment income tax for each year and the deduction
therefor.
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