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Mr. Woll, and John Laviano. Petitioner commenced business on
December 1, 1982.
Petitioner conducted the same business as Components; the
only changes were the addition of the word “International” to the
name and the change in ownership percentages. All of Components'
accounts and sources of supply that were developed prior to
petitioner's organization, and all employees who were trained
prior to the organization of petitioner, were transferred to
petitioner.
a. Mr. Laviano
Mr. Laviano was petitioner's president. He received a
bachelor of science degree in accounting from St. John's
University in 1977. After graduating from college, Mr. Laviano
worked for Semi-Specialists of America, Inc. (SAI), one of the
largest and most profitable semiconductor brokerages in the
nation. SAI was an electronics business that functioned as a
middleman for computer chips and other electronic components,
much as petitioner did. Mr. Laviano worked for SAI for
approximately 1 year. While he was employed there, Mr. Laviano
learned SAI's business well enough to go into the business for
himself. During the year in issue, Mr. Laviano worked for
petitioner approximately 60 to 80 hours per week, 52 weeks per
year. Mr. Laviano was a devoted workaholic who was committed to
petitioner's business and success.
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