Anthony Teong-Chan Gaw as Transferee of Radcliffe Investment LTD. - Page 9

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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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