Sam Kong Fashions, Inc. - Page 9

                                        - 9 -                                         
               Reported                      1994             1995                    
               Gross receipts/sales          $224,718       $217,296                  
               Deductions:                                                            
               Compensation to               14,520         --                        
               officers                                                               
               Salaries and wages            122,528        119,170                   
               Rents                         24,475         29,026                    
               Taxes and licenses            16,719         14,880                    
               Depreciation                  20,180         17,680                    
               Other deductions              26,268         36,387                    
               Taxable income           28                       153                  
               Total tax                     4                   23                   
               In preparing the 1995 corporate income tax return of Sam               
          Kong Fashions, an employee of Kim Y. Ling, P.C., made a                     
          mathematical mistake in calculating the gross receipts.  The                
          employee listed the corporation’s gross receipts as $217,296.06             
          instead of $241,890.9                                                       
               Sam Kong Fashions did not claim a deduction for the cost of            
          thread used in its sewing business on its 1994 corporate income             
          tax return.  On its 1995 corporate income tax return, the                   
          corporation reported a business expense deduction of $12,013 for            
          the cost of thread.10                                                       
               In 1994 and 1995, Kim Y. Ling, P.C., prepared a depreciation           
          schedule for the equipment purchased by Sam Kong Fashions.  Kim             


               9 The parties agree that the sum of the 1995 gross receipts            
          reported to Kim Y. Ling, P.C., totaled $241,890.                            
               10 On brief, petitioners assert that either Mr. Kong or Sam            
          Kong Fashions is entitled to a deduction of at least $40,000 to             
          $50,000 for thread used in its sewing business in 1994.                     





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