Paul Bi-Yang Chen and Chiu-Mei Chen - Page 1

                                 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                  
               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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