- 5 - Mr. Wen’s shares of stock. Sam Kong Fashions paid Mr. Wen $50,000 for his 50 shares of stock. From April 1994 to December 1995, Mr. Kong was the sole shareholder of Sam Kong Fashions. During the taxable years in issue, Sam Kong Fashions engaged in the business of sewing garments as a subcontractor for other companies in the garment business.4 It performed sewing services for Style Setter Fashions, Inc. (Style Setter), Half Moon Bay, Inc. (Half Moon Bay), and East West Manufacturing, Inc. (East West). Sam Kong Fashions delivered the completed garments to the contractors, and the contractors paid Sam Kong Fashions per completed garment. Mr. Kong provided hangers and bags to the contractors as an accommodation; the contractors paid for the bags and hangers in addition to the per garment fee. At least one contractor created different invoices and issued separate checks for the hangers and bags. During 1994, Style Setter issued 48 checks to “Sam Kong”, which totaled $592,370.50.5 Sam Kong Fashions deposited only 16 of these checks into its business checking account maintained at 4 Generally, Sam Kong Fashions assembled garments using cut pieces supplied by the contractors. 5 On the basis of the evidence presented, we calculate that these 48 checks total $592,550.50. Because respondent requests that we find that the 1994 Setter Style checks issued to Mr. Kong total $592,370.50, we shall use respondent’s figure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011