T.C. Memo. 2006-160
UNITED STATES TAX COURT
PAUL BI-YANG CHEN AND CHIU-MEI CHEN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15579-04. Filed August 8, 2006.
John Gigounas, Edward Simpson, and Gerald Holmes, for
petitioners.
Huong T. Duong, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HOLMES, Judge: Paul Chen and his wife, Chui-Mei, were both
officers of a closely held business, PCTI. PCTI was a successful
wholesaler of computer components for a few years, but it began
having a cashflow problem in 1998. Mr. Chen tried to solve the
problem by committing insurance fraud. The fraud unraveled, and
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