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Some of the facts have been stipulated and are so found.
The stipulations and attached exhibits are incorporated herein by
this reference.
The Lees are husband and wife. They resided in Elmhurst,
New York, when they petitioned the Court. They filed joint
Federal income tax returns for the years in issue. Hamalee is
Mr. Lee's wholly-owned corporation. Hamalee was formed by Mr.
Lee in 1982 under the corporate laws of the State of New York,
and it became an S corporation as of June 1, 1987. Hamalee's
mailing address was in Elmhurst, New York, at the time of its
petition.
The Lees immigrated to the United States from South Korea in
1980. While in Korea, Mr. Lee received a college degree in
economics, and Mrs. Lee completed some college courses. Mr. Lee
managed one company while in Korea, and he owned and operated a
second company there for 12 years. When the second company
terminated in 1979, its gross sales were approximately $500,000,
and it employed approximately 300 people. Mrs. Lee worked with
Mr. Lee at the second company before it terminated.
Hamalee was a wholesale supplier of beer in the Long Island
area of New York. The Lees were its only officers; Mr. Lee
served as its president, and Mrs. Lee served as its secretary.
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