Andrew Chook - Page 2

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          for decision are:  (1) Whether petitioner received but did not              
          report income in the form of nonemployee compensation paid to him           
          by Unwrapped, Inc. (Unwrapped); (2) whether petitioner is liable            
          for a fraud penalty under section 6663(a),2 or in the                       
          alternative, an accuracy-related penalty under section 6662(a);             
          and (3) whether petitioner is liable for a penalty under section            
          6673(a)(1)(C) for unreasonable failure to pursue available                  
          administrative remedies.                                                    
                                  FINDINGS OF FACT                                    
               Petitioner did not cooperate with respondent in preparing a            
          stipulation of facts.  At the time he filed his petition,                   
          petitioner resided in Brockton, Massachusetts.                              
               During 2002, petitioner operated Liberty Temporary Agency              
          (Liberty Temp).3  While the nature of Liberty Temp is unclear, it           
          appears that Liberty Temp provided temporary workers to                     
          Unwrapped, Inc. (Unwrapped), a “production stitching” company.              
          During 2002, Unwrapped issued checks totaling $447,084 to                   
          “Liberty Temp--D/B/Andrew Chook”, which petitioner endorsed and             


               1(...continued)                                                        
          amounts are rounded to the nearest dollar.                                  
               2  Respondent asserted that petitioner was liable for a                
          fraud penalty under sec. 6663(a) in an amendment to answer,                 
          discussed infra.                                                            
               3  On Sept. 23, 1993, an employer identification number was            
          assigned to Liberty Temp, and a Notice of New Employer                      
          Identification Number Assigned was mailed to Liberty Temp and               
          Richard Nguon.                                                              




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