T.C. Memo. 2006-193
UNITED STATES TAX COURT
KAI H. and SUSANNA LEE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
ULYSSES K. and JANE LEE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 16601-04, 16602-04. Filed September 11, 2006.
Roger Adams, for petitioners.
John D. Faucher, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HOLMES, Judge: In 1999 and 2000, Ulysses Lee was a full-
time employee of the IRS; his brother, Kai, worked as a doctor
and professor and ran several other businesses. One of these
businesses was Lee Brothers Investments, a real estate investment
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