Kai-Chung C. and Meekhing T. Lam - Page 2

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          penalty under section 6662(a).1  For 1995, respondent determined            
          a $25,759 deficiency and a $5,152 accuracy-related penalty.  For            
          1996, respondent determined a $24,587 deficiency and a $4,917               
          accuracy-related penalty.                                                   
               After concessions,2 there are three issues for decision.               
          The first issue is whether petitioners substantiated various                
          business expenses they claimed in each of the years at issue.  We           
          hold that petitioners did not substantiate any of these expenses.           
          The second issue is whether petitioners failed to report $3,424             
          of rental income in 1996.  We hold that they did.  The third                
          issue is whether petitioners are liable for the accuracy-related            
          penalty for each of the years at issue.  We hold that they are.             
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and accompanying exhibits, the                     
          supplemental stipulation of facts, and the second supplemental              
          stipulation of facts are incorporated by this reference.                    




               1All section references are to the Internal Revenue Code in            
          effect for the years at issue, and all Rule references are to the           
          Tax Court Rules of Practice and Procedure, unless otherwise                 
          indicated.  Amounts have been rounded to the nearest dollar.                
               2Petitioners conceded the increases in rental income                   
          respondent determined for 1994 and 1995 and certain business                
          expenses respondent disallowed for each of the years at issue.              
          Respondent conceded certain disallowed business expenses that               
          petitioners claimed for each of the years at issue.                         





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