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168 GARMENT, INC. v. COMMISSIONER

Dkt. Nos. 9243-04, 17152-04, 17153-04.

91 T.C.M. 734 (2006)

T.C. Memo. 2006-23

168 Garment, Inc., et al. v. Commissioner.

United States Tax Court.

February 14, 2006.

Attorney(s) appearing for the Case

Lang Thi Ngo, pro se.

Michael W. Berwind, for respondent.

168 GARMENT, INC., ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

MEMORANDUM OPINION

FOLEY, Judge:

The issues for decision are whether 168 Garment, Inc. (168 Garment), and Lang Thi Ngo (Ms. Ngo) failed to report income and are liable for the section 66632 fraud or the section 6662 accuracy-related penalty.

Background

In 1997, pursuant to California law, Ms. Ngo incorporated 168 Garment, which performed sewing services for various garment manufacturers. Ms. Ngo was the...

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