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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