Paul Bi-Yang Chen and Chiu-Mei Chen - Page 2

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          both Chens pleaded guilty to a variety of crimes.  Neither PCTI             
          nor the Chens reported the proceeds of the fraud as income.  The            
          Chens contest the resulting deficiency and fraud penalty.  Mrs.             
          Chen seeks innocent spouse relief.                                          
                                     Background                                       
               The Chens came to the United States in 1985 from Taiwan,               
          where Mr. Chen had graduated from college and earned master’s               
          degrees in civil engineering and architecture.  He had taught               
          high school for 20 years in Taiwan, but after immigrating he                
          switched fields and worked for his brother’s computer business.             
          In 1991, he started up his own firm and began wholesaling                   
          computer parts under the name PC Team.  Within two years, he                
          incorporated that business as PCTI.  He was PCTI’s sole                     
          shareholder and its president, and he named Mrs. Chen vice                  
          president and administrator.  She worked at PCTI full time,                 
          managing the company’s inventory and running the business when              
          Mr. Chen was away.  She had full authority to sign checks and tax           
          returns on behalf of PCTI, though the parties stipulated that she           
          does not read, write, or speak English.                                     
               PCTI made a valid S corporation election in 1995 and was               
          still an S corporation in 1998, the tax year at issue.  Its                 
          accounting system was not complex--Mr. Chen simply dictated the             
          company’s financial transactions to Bo Hua He, PCTI’s in-house              
          accountant.  Ms. He also prepared many of the checks for the                






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