Paul Bi-Yang Chen and Chiu-Mei Chen - Page 16

                                       - 16 -                                         
          Commissioner, 77 T.C. 582, 598 (1981).  The Chens did not do this           
          and so cannot offset their 1998 gross income with a business bad            
          debt deduction.                                                             
                                     Conclusion                                       
               We reject each of the Chens’ arguments.  Because of the                
          fraud involved, the IRS has no time limit for assessing the                 
          unpaid tax, so the statute of limitations had not passed.                   
          Unreported income of $272,963 was omitted from the Chens’ 1998              
          return.  The Chens are liable for the fraud penalty due to their            
          intentional failure to report the insurance proceeds.  And                  
          finally, Mrs. Chen does not qualify for innocent spouse relief.             
          To reflect the Commissioner’s concession, however,                          

                                             Decision will be entered under           
                                        Rule 155.                                     





















Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  

Last modified: May 25, 2011