Khen T. Huynh - Page 3

                                        - 3 -                                         
               In 1996 and 1997, the insurers paid $9,719 and $9,631,                 
          respectively, to the credit card companies on Hong’s behalf.                
               For 1996 and 1997, petitioner prepared her and Hong’s joint            
          Federal income tax returns.  On their tax returns, petitioner and           
          Hong, apparently under the impression that these amounts did not            
          constitute taxable income, did not report the above insurance               
          payments that had been made on Hong’s behalf.                               
               Upon audit for 1996 and 1997, respondent determined that the           
          insurance payments constituted taxable income.  In connection               
          with respondent’s audit, Hong explained to petitioner that                  
          respondent’s adjustments were related to the taxability of the              
          insurance payments made on his behalf.                                      
               On December 15, 1998, and October 13, 1999, respectively,              
          respondent’s notices of deficiency relating to petitioner and               
          Hong’s 1996 and 1997 joint Federal income tax returns were mailed           
          to petitioner and Hong.                                                     
               With regard to the notice of deficiency for each year,                 
          petitioner and Hong jointly filed petitions with the Tax Court to           
          redetermine the deficiencies, and petitioner read and signed both           
          petitions.  The two cases were consolidated for trial.                      
               Prior to the trial, petitioner and Hong attended meetings              
          with respondent’s Appeals Office and meetings with counsel for              
          respondent.  Petitioner spoke and participated in these meetings,           
          and petitioner signed various documents including a stipulation             






Page:  Previous  1  2  3  4  5  6  7  Next

Last modified: May 25, 2011