- 34 - In 1994 and 1995, petitioners understated their incomes by substantial amounts. 2. Implausible or Inconsistent Explanations of Behavior Petitioners also offered implausible explanations for failing to deposit customer checks into the checking account of Sam Kong Fashions. Petitioners assert that the contractors issued the checks payable to Mr. Kong because he provided services to the contractors. Yet, representatives of Style Setters and Half Moon Bay testified that the checks in the record were issued to Sam Kong Fashions, not Mr. Kong. Furthermore, Mr. Kong acted inconsistently with this explanation because he listed wages from Sam Kong Fashions as his only source of income on his 1994 and 1995 income tax returns. Petitioners’ explanations are also inconsistent with how Sam Kong Fashions processed customer checks. Sam Kong Fashions deposited numerous checks payable to “Sam Kong” into its business checking account. Nothing on the face of these checks explains why some checks issued to Mr. Kong were deposited into Sam Kong Fashions’s business account while others were deposited into Mr. Kong’s personal checking account. Similarly, several checks issued to Sam Kong Fashions were deposited into Mr. Kong’s personal account. From the inconsistent treatment of customer checks, we infer that petitioners attempted to hide the receiptPage: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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