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February 1985 and the remaining 12-percent interest for
$1,000,000 in March 1986. Radcliffe also owned an interest in
the Meridien Hotel in San Francisco.
During relevant periods, NMSC was a California general
partnership that was formed to acquire commercial office build-
ings located at 55 Hawthorne Street and 631 Howard Street in San
Francisco. During at least a portion of the years at issue,
Lyman Jee (Mr. Jee) was a partner of Radcliffe in NMSC.
Petitioner's father, S.C. Gaw, wholly owned Radcliffe as of
the time of his death in October 1983. After S.C. Gaw's death,
pursuant to discussions and an agreement among petitioner, his
mother, and his siblings (family property division), it was
determined that petitioner was to receive the stock of Radcliffe
that his father had owned, and petitioner acquired all of the
stock of Radcliffe no later than July 1984. During relevant
periods, petitioner was chairman and president of Radcliffe, and
his wife, Rossana W. Gaw (Ms. Gaw) was its secretary and treas-
urer.
During the years at issue, the net worth of Radcliffe
(including all loan liabilities) was not less than $6,033,039.
Radcliffe was liquidated on December 23, 1986, and all of
Radcliffe's corporate assets, which had a net value in excess of
liabilities of at least $1,000,000, were transferred to peti-
tioner as its sole shareholder.
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