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and petitioner’s three children attended private schools.
Mr. Makalintal and petitioner would occasionally take vacations
to a mountain resort in the Philippines.
While living in the Philippines, petitioner knew the amount
of Mr. Makalintal's salary from ICPI, but petitioner did not know
how much income Mr. Makalintal was earning from his other
businesses and investments. Mr. Makalintal did not discuss any
significant aspects of his businesses and investments with
petitioner.
In December of 1984, Mr. Makalintal purchased for $600,000
investment real property in Tiburon, California (Tiburon
Property). Mr. Makalintal made a cash downpayment of
approximately $300,000 and financed the balance of the purchase
price for the Tiburon Property.
As indicated, in 1985, Mr. Makalintal, petitioner, and their
three children moved to the United States. Mr. Makalintal was
issued by the United States a non-immigrant visa that was valid
through February of 1989. Apparently, Mr. Makalintal now lives
in the Philippines. The record does not indicate whether
Mr. Makalintal ever became a U.S. citizen.
Petitioner is now a citizen of the United States and a
resident of Sunnyvale, California.
In August of 1985, after Mr. Makalintal, petitioner, and
their three children moved to the United States, Mr. Makalintal
purchased for $466,438 a home in Greenbrae, California (the
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