Charles Y. and Jin Y. Choi - Page 6




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          “cash” from the deposit account in the total amount of                      
          $1,293,600, $582,200 of which was deposited into the operating              
          account.                                                                    
               In 1992, petitioner purchased a house in Glendale, Arizona,            
          for $208,250.  A downpayment of $41,650 was made on the home.               
          Petitioner applied for a loan to finance the purchase.  He                  
          reflected on the loan application that the net worth of Gene’s              
          was $269,115 and that his monthly income from Gene’s was $7,197.            
          In 1994, petitioner sold Gene’s for $259,790.                               
               On their 1991, 1992, and 1993 income tax returns,                      
          petitioners reported net profit from Gene’s of $6,696, $13,363              
          and $67,126, respectively.  On the 1991 and 1992 returns,                   
          petitioners claimed petitioner’s parents and brother as                     
          dependents.  Petitioner knew that the gross receipts reported for           
          1991 through 1993 were understated.  He omitted some gross                  
          receipts in order to avoid tax so that he would have more                   
          retained cash.                                                              
               Respondent conducted a civil examination of petitioners’               
          income tax returns, and petitioners did not provide the internal            
          revenue agent with the cash register tapes.  Invoices for                   
          purchases by check were presented, but no invoices were provided            
          for cash purchases.  During the examination, petitioner stated              
          that he was the sole source of support of his parents.                      








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