Chen v. Comm'r

PAUL BI-YANG CHEN AND CHIU-MEI CHEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Chen v. Comm'r

No. 15579-04

United States Tax Court

T.C. Memo 2006-160; 2006 Tax Ct. Memo LEXIS 163;

August 8, 2006, Filed

John Gigounas, Edward Simpson, and Gerald Holmes, for petitioners.

Huong T. Duong, for respondent.

Holmes, Mark V.

Mark V. Holmes

MEMORANDUM FINDINGS OF FACT AND OPINION

HOLMES, Judge: Paul Chen and his wife, Chui-Mei, were both officers of a closely held business, PCTI. PCTI was a successful wholesaler of computer components for a few years, but it began having a cashflow problem in…