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FINDINGS OF FACT
Some of the facts have been stipulated and are found
accordingly.
Petitioner Apollo Overseas International, Inc., is a
California corporation with its principal place of business in
Santa Fe Springs, California, at the time of the filing of the
petition in this case. Petitioner filed a Federal income tax
return for each of its taxable years ending January 31, 1988,
1989, and 1990 with the Internal Revenue Service Center in
Fresno, California.
Petitioner was engaged in the business of importing clothing
(garments) and cloth badges (badges) manufactured in Taiwan and
reselling them as a wholesaler to retailers in the United States.
Petitioner commenced this business in 1987.
Ms. Michelle Chiou (Ms. Chiou) was petitioner's president
and chief executive officer during the years here in issue.
Prior to the taxable year ending January 31, 1990 (fiscal year
1990), Ms. Chiou was petitioner's only employee. During its
fiscal year 1990, petitioner had one other employee.
Petitioner's stock was owned half by Ms. Chiou and half by Alan
Chih-Kuo Tai.
Petitioner purchased garments from a number of suppliers in
Taiwan, one of which was Apollo Free Industrial Co., Ltd.
(Taiwan), a corporation formed under the laws of Taiwan (Apollo
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