Michael Chin and Julie Hedrich Chin - Page 4




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               On November 18, 1991, the Skin Service Club, Inc. (Skin                
          Service Club), was incorporated as a C corporation under                    
          California law.   Petitioner and his brother, David Sywehong                
          Chin, each owned 50 percent of the Skin Service Club stock.  Two            
          years later, on November 15, 1993, the Skin Service Club elected            
          to be taxed as an S corporation.                                            
               The Skin Service Club conducted business at the Sherman Oaks           
          Property in 1992, 1993, and 1994.  Petitioner, however, did not             
          acquire, in his name, any City of Los Angeles permits or licenses           
          needed to conduct business in the town of Sherman Oaks.  In                 
          addition, petitioner never maintained a medical or surgical                 
          listing in any Sherman Oaks telephone directory, and he was not a           
          member of the Los Angeles County Medical Society.                           
               For both years at issue, the Skin Service Club reported zero           
          gross receipts.  Further, the Skin Service Club did not generate            
          any revenue from the time of its conversion to an S corporation             
          through December 30, 1996, when the company was dissolved.                  
          During its entire period of operation, the Skin Service Club did            
          not claim any rent expense relating to the Sherman Oaks Property.           
               On November 13, 1991, petitioner executed a 10-year lease on           
          suite B of the Sherman Oaks Property, with petitioner’s mother as           
          landlord.  Under the terms of the lease, petitioner made rent               
          payments to his mother of $52,000 in 1994 and $48,000 in 1997.              
          Petitioner deducted these amounts as business expenses on his               





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