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 1998. Mr. Chen tried to solve the problem by committing insurance fraud. The fraud unraveled, and both Chens pleaded guilty to a variety of crimes. Neither PCTI nor the Chens reported the proceeds of the...
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