Apollo Overseas International, Inc. - Page 3

                                        -  -3                                           
                                  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             






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011