Sam Kong Fashions, Inc. - Page 35

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          of income and avoid the payment of taxes.  We find petitioners’             
          explanation implausible.                                                    
                    3.   Failure To Provide Return Preparer With Accurate             
                         and Necessary Information                                    
               Petitioners also failed to provide their tax preparer with             
          all the information and records necessary to prepare their 1994             
          and 1995 individual and corporate income tax returns.  Mr. Ling             
          informed Mr. Kong that all income should be reported and all                
          corporate receipts should be deposited into a corporate account.            
          When Mr. Kong provided information to Kim Y. Ling, P.C., to                 
          prepare the individual and corporate income tax returns in 1994             
          and 1995, Mr. Kong failed to inform the tax preparer that a large           
          portion of the corporate receipts had not been deposited into the           
          corporate account.  Mr. Kong did not advise Kim Y. Ling, P.C., of           
          additional unreported income until after respondent began his               
          investigation.  We believe that Mr. Kong intended to reduce taxes           
          by concealing corporate receipts and by failing to provide this             
          information to his accountant.  See Federbush v. Commissioner, 34           
          T.C. at 750.                                                                
                    4.   Maintaining Inadequate Books and Records                     
               Sam Kong Fashions failed to maintain adequate books and                
          records and failed to maintain correct records of its gross                 
          receipts.  Petitioners have failed to offer any records from Sam            
          Kong Fashions to show the number of full- and part-time                     
          employees, the hours that these employees worked, or the hourly             





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