Andrew Chook - Page 1

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                                 T.C. Memo. 2007-17                                   


                               UNITED STATES TAX COURT                                


                             ANDREW CHOOK, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 4526-05.              Filed January 29, 2007.               


               Thomas Stylianos, Jr., for petitioner.                                 
               Michael R. Fiore, for respondent.                                      


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               HAINES, Judge:  Respondent determined a deficiency in                  
          petitioner’s 2002 Federal income tax of $171,823 and an accuracy-           
          related penalty under section 6662(a) of $34,365.1  The issues              

               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code, as amended, and all Rule references              
          are to the Tax Court Rules of Practice and Procedure.  All                  
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