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his mother-in-law Mme. Y.C. Koo (Mme. Koo) owned stock in
Pioneer.
Throughout the years at issue until at least the time of the
trial of these cases, petitioner was the managing director and
chairman of Pioneer. Petitioner became managing director of
Pioneer in 1973 at the behest of Mme. Koo. He became chairman of
that company after the death of his father in October 1983. Ms.
Gaw also was a director of Pioneer during the years at issue.
Prior to and during the years at issue, Pioneer wholly or
partially owned a number of corporations, including its two
wholly owned subsidiaries Multi-Credit Finance Co. Ltd. (Multi-
Credit), which was incorporated in Hong Kong, and Mandalay
Investments Ltd. (Mandalay). At least prior to the years at
issue, petitioner was president and secretary of Multi-Credit.
Prior to those years and at least during 1985 and 1986, peti-
tioner was managing director of Multi-Credit, and at least during
1986, Ms. Gaw was one of its directors. At least during 1984,
petitioner was president of Mandalay and Ms. Gaw was its execu-
tive director and secretary.
2. Traveluck Investments, Inc.
Traveluck Investments, Inc. (Traveluck) was incorporated in
Liberia, and, at all relevant periods after January 3, 1985, one
share of the stock of Traveluck was held in the name of Mme. Koo.
At least during 1985, petitioner was a director of Traveluck.
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