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The Takaos and Edwin Nakamura (Nakamura) owned all of the
interests in Toraya Apartments Partnership (Toraya Apartments),
of which Nakamura was the managing general partner. Toraya
Apartments' sole asset was a building located at 1734 Post
Street, San Francisco, California. That building housed
apartments and the Post Street restaurant. In 1991, the Kudos
received two checks from Toraya Apartments in the amounts of
$2,269.14 and $1,400, which were deposited in the Sumitomo
account.
The Kudos have three children, including Nicholas, who was
unable to speak until he was 8 years old. Nicholas' problem
required the Kudos to take him to several different doctors and
various therapists and specialists. Although at one point the
Kudos were advised that Nicholas would never speak or hear, he
began to speak when he was about 8 years old. He was 11 years
old at the time of trial. Nicholas' medical expenses generally
were not covered by insurance although some of his expenses may
have been reimbursed by insurance in 1990 and 1991. The Kudos
did not claim any deductions for medical or dental expenses on
their 1990 or 1991 income tax return.
The Kudos' relatives in Japan knew of Nicholas' condition,
and from time to time they would send small amounts of money to
help pay for his treatment.8 Scott's parents had helped his
8 Exhibit 6, which consists of four undated letters that
apparently accompanied "small" money donations (according to the
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