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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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Last modified: May 25, 2011