Kaing Chin and Hae Kyung Baek - Page 1

                                 T.C. Memo. 2004-189                                  

                               UNITED STATES TAX COURT                                

                    KAING CHIN AND HAE KYUNG BAEK, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 8740-03.              Filed August 24, 2004.                

               Sang I. Lee, for petitioners.                                          
               Alan H. Cooper and Lauren Mark, for respondent.                        

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               LARO, Judge:  Petitioners petitioned the Court to                      
          redetermine respondent’s determinations as to their 1999 Federal            
          income tax.  As to that year, respondent determined in the notice           
          of deficiency that petitioners were liable for a $154,896                   
          deficiency and a $30,979.20 accuracy-related penalty under                  

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