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Greenbrae home). Mr. Makalintal made a cash downpayment of
$200,000 and financed the balance of the purchase price for the
Greenbrae home. The Greenbrae home had 6 bedrooms and 3-� baths.
In 1985, Mr. Makalintal organized the following three
California corporations: Integrated Systems and Support (ISS),
Magnacad International (Magnacad), and Magna Financial and
Management Corp. (MFMC) (hereinafter sometimes referred to as the
California corporations).
ISS was organized to market and sell in the United States
semiconductors manufactured in the Philippines by ICPI. Magnacad
was organized to purchase in the United States raw materials
needed by ICPI for the manufacture of semiconductors. The
purpose for MFMC is not made clear in the record.
Mr. Makalintal owned 100 percent of the stock in ISS and
MFMC. Mr. Makalintal owned 30 percent, and Jose Santos,
petitioner's brother, owned 70 percent of the stock in Magnacad.
Petitioner did not own stock in any of the California
corporations.
Mr. Makalintal was president, and petitioner nominally was
secretary of each of the above California corporations.
Petitioner, at the direction of Mr. Makalintal, signed the
articles of incorporation of each of the California corporations.
During the years in issue, Mr. Makalintal managed and
operated each of the California corporations out of the Greenbrae
home.
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