Joseph D. and Mi Jung Park, et al. - Page 2




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                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               FOLEY, Judge:  By notices dated June 7 and 8, 1999,                    
          respondent determined deficiencies, additions to tax, and                   
          penalties relating to petitioners’ Federal income tax as follows:           

                       Joseph D. and Mi Jung Park, docket No. 13778-99                
                                        Additions to Tax                              
               Year      Deficiency     Sec. 6651(a)(1)2    Sec. 6662(a)              
               1992      $105,638       $26,407             $21,128                   
               1993      157,576        39,394              31,515                    
                             John N. Park, docket No. 13784-99                        
                                        Additions to Tax                              
               Year      Deficiency     Sec. 6651(a)(1)     Sec. 6662(a)              
               1990      $321,294       $79,401             $64,259                   
               1991      128,427        31,142              25,685                    
               1992      118,697        5,920               23,739                    
               1993      654,754        163,360             130,951                   
                       David S. and Deborah Park, docket No. 13789-99                 
                                        Additions to Tax                              
               Year      Deficiency     Sec. 6651(a)(1)     Sec. 6662(a)              
               1992      $100,630       $25,097             $20,126                   
               1993      101,233        --                  20,247                    
               1994      237,580        --                  47,516                    

               The issues for decision are whether petitioners:  (1)                  
          Underreported income during the years in issue, and (2) are                 
          liable for section 6651 additions to tax and section 6662(a)                
          accuracy-related penalties.                                                 




               2  All section references are to the Internal Revenue Code             
          in effect for the years in issue, and all Rule references are to            
          the Tax Court Rules of Practice and Procedure.                              





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