Shigenori Kudo and Motomi Kudo, et al. - Page 16

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               Yoshinori was born in the United States in 1924.  He                   
          attended school here through third grade.  When he was 8 years              
          old, Yoshinori's father died and Yoshinori and his mother moved             
          to Japan.  Yoshinori completed his education through 2 years of             
          college in Japan.  Yoshinori married Akiko in Japan in 1951.                
          They moved to the United States in December 1958.  Yoshinori's              
          understanding of English was not very good, and he testified with           
          the aid of an interpreter.                                                  
               Akiko was born in Japan.  She could speak and understand               
          very little English.  She could not write checks or drive.                  
          Nevertheless, Akiko handled the family's personal financial                 
          affairs and controlled all the Takaos' personal savings and bank            
          accounts.                                                                   
               During the years in issue and for prior years, the Takaos              
          owned individually a Japanese restaurant located at 1914 Fillmore           
          Street, San Francisco, California (Fillmore Street restaurant),             
          which was managed by the Takaos' younger son, Frank Takao.  The             
          Fillmore Street restaurant operated under the name "Toraya".                
          Yoshinori purchased the Fillmore Street restaurant, his first               
          restaurant, in 1965.                                                        
               During the years in issue the Takaos owned 100 percent of              
          the shares of Toraya, which owned and operated the Berkeley                 
          restaurant and the Post Street restaurant in 1988 and 1989.  They           
          operated also under the name "Toraya".  Junichi, the Takao's                
          oldest son, managed the Berkeley restaurant.  Toraya closed the             




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