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B. BOT
BOT, which was incorporated in California in 1979 and
conducted business there during the years at issue, was
organizedto invest in 300 Montgomery Associates (300 Montgomery
Associates) in San Francisco. In 1979, BOT acquired an 80-
percent interest in 300 Montgomery Associates that it held during
the years at issue. During relevant periods, 300 Montgomery
Associates was a California general partnership that owned a
commercial office building located at 300 Montgomery Street in
San Francisco. Mr. Jee was BOT's partner in 300 Montgomery
Associates during the years at issue.
When BOT was incorporated and throughout the years at issue
until December 29, 1986, its sole shareholder was Pempire Invest-
ment Ltd. (Pempire), which was incorporated in Liberia on Novem-
ber 6, 1978. Prior to the time at which petitioner acquired all
the stock of Pempire, it was wholly owned by Merit Investment
Co., Inc. (Merit), which was also incorporated in Liberia.
S.C. Gaw wholly owned the stock of Merit as of the time of
his death in October 1983. Pursuant to the family property
division with his mother and siblings, petitioner acquired all of
the stock of Pempire, and therefore acquired indirectly all of
the stock of BOT, no later than July 1984. At least during 1984,
petitioner was chairman and president of Pempire. During rele-
vant periods, petitioner was chairman and president of BOT, and
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