Eng Guek Kang - Page 4




                                        - 3 -                                         
          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.                                                                   





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