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Charles Y. Choi
Addition to Tax
Year Deficiency Sec. 6663
1991 $59,106 $44,330
Charles Y. and Jin Yi Choi
Additions to Tax and Penalties
Year Deficiency Sec. 6651(a)(1) Sec. 6663
1992 $49,624 -— $37,218
1993 34,177 $39,613 25,633
The issues remaining for our consideration are: (1) Whether
Charles Y. Choi (petitioner) understated income for the taxable
year 1991; (2) whether petitioners understated income for the
taxable year 1992; (3) whether petitioner is liable for the civil
fraud penalty under section 66631 for the taxable years 1991; (4)
whether petitioners are liable for an addition to tax for
delinquent filing of their return for 1993; (5) whether
petitioners are liable for self-employment tax on their earnings
from Gene’s Modern Market; and (6) whether petitioners provided
over one-half of the support of James Choi during 1991 and 1992
so as to be entitled to claim him as a dependent.
FINDINGS OF FACT
Petitioner and Jin Y. Choi were married in 1992 and resided
in California at the time their petition was filed. During 1991
through 1993, petitioner was the sole proprietor of Gene’s Modern
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code for the years in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
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