Charles Y. and Jin Y. Choi - Page 4




                                        - 4 -                                         
          Gene’s.  Petitioner provided the daily summary sheets to Mr. Kim            
          every month.                                                                
               Petitioner knew that the amounts of gross receipts provided            
          to Mr. Kim were less than the actual gross receipts for Gene’s.             
          As an example, the cash register tapes for August 1, 1992,                  
          totaled $2,925.72, whereas petitioner’s summary sheets given to             
          Mr. Kim reflected total sales of $1,325.42.  Mr. Kim prepared               
          yearly summaries based on the daily summary sheets received from            
          petitioner and used the summaries to prepare the Schedules C,               
          Profit or Loss From Business, for Gene’s that were included with            
          petitioners’ Federal income tax returns.  Petitioner did not                
          provide Mr. Kim with the register tapes from Gene’s.  In                    
          addition, Mr. Kim was provided with inaccurate (understated)                
          records of cash inventory purchases.                                        
               Petitioner’s method of accounting for Gene’s receipts and              
          expenditures caused the omission and understatement of income for           
          the years in issue.  During the examination of petitioners’                 
          Federal income tax returns, petitioner estimated and represented            
          to respondent’s agent that he had understated Gene’s gross                  
          receipts by approximately $15,000 per month.  Petitioner, on the            
          basis of the actual cash register receipts, determined that                 
          Gene’s gross receipts during 1991 and 1992 were $50,000 to                  
          $60,000 per month or $600,000 to $720,000 per year, respectively.           
          On the Schedules C of the 1991 and 1992 income tax returns, gross           






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