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pursuant to section 7430 and Rule 231.2 This Court ruled in
favor of petitioners, in Park v. Commissioner, T.C. Memo. 2002-
50, and we incorporate herein by reference the facts set forth in
that opinion.
Background
John, Joseph, and David Park are brothers who immigrated to
the United States from Korea in the 1980s. During the years in
issue, Joseph and David Park were married to Mi Jung and Deborah
Park, respectively. Petitioners moved to Florida to establish
businesses and resided there when they filed their petitions.
Respondent was suspicious of the inconsistencies between
petitioners’ lifestyles and their reported income for tax years
1990 to 1994. Respondent believed petitioners were “skimming”
money from their businesses, “laundering” money, or buying
discounted traveler’s checks and selling them at a profit.
Kaharudin Latief and Ferry Tandiono, both wealthy
Indonesian businessmen, transferred more than $9 million, via
wire transfers and traveler’s checks, to petitioners.
Petitioners worked together on several of the business ventures
and would, at times, transfer funds amongst themselves. In
addition, Mr. Tandiono provided David with over $1 million to buy
2 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect at relevant times, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
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Last modified: May 25, 2011