Anthony Teong-Chan Gaw as Transferee of Radcliffe Investment LTD. - Page 8

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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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