Kai H. and Susanna Lee - Page 8

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               And here are a few from Kai’s:                                         
               !    186 hours in 1999 to show a single vacant apartment to            
                    prospective tenants.                                              
               !    200 hours of answering calls from prospective tenants             
                    in both years.                                                    
               !    48-50 hours to wrap coins from laundry machines in one            
                    of the apartment buildings.                                       
               But because the brothers had to show not only the time they            
          spent on partnership business, but that it was greater than the             
          time they spent on other jobs, the exaggeration in their logs of            
          real estate work was matched by understatements of time spent at            
          their full-time jobs.  Ulysses calculated his hours spent working           
          for the IRS by deducting his sick leave and vacation from a full-           
          time schedule.  But the Commissioner introduced time and                    
          attendance records from the IRS, showing that Ulysses hadn’t used           
          all his available sick and annual leave.  This forced him to take           
          the dubious position that he routinely filled in his own time-              
          and-attendance records inaccurately.                                        
               Kai Lee’s testimony on this point was no better.  He swore             
          that he worked for the corporation that he owned--a corporation             
          that produced more than $60,000 in gross receipts for both years            
          --only 37 hours in 1999, and 3 hours in 2000.  He likewise                  
          claimed to have spent only 135 hours working for 101 Positron               
          (the diagnostic facility that he owned and operated).  But when,            
          during the exam process, he argued that 101 Positron was not a              
          passive activity, he told the appeals officer that he spent “at             





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