Jung K. Yoon and Hee S. Yoon - Page 3

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          to the stipulation of facts and supplemental stipulation of facts           
          and an additional exhibit produced at trial.                                
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.  At the           
          time the petition was filed, Jung K. Yoon and Hee S. Yoon                   
          (petitioners) resided in El Paso, Texas.                                    
               Jung K. Yoon (Yoon) was born in Seoul, Korea.  Yoon                    
          immigrated to the United States in 1975.                                    
               During 1989, 1990, and 1991, petitioners owned and operated            
          a general merchandise store specializing in low-cost items in               
          South El Paso under the name L.A. Trading.  Most of petitioners'            
          customers came into the United States from Juarez, Mexico.                  
          During the years in issue, Yoon worked 14 hours a day, 7 days a             
          week, and he never took a vacation.                                         
               In 1989, L.A. Trading was operated as a sole proprietorship.           
          On January 31, 1990, petitioners incorporated Jung K. Yoon, Inc.            
          (JKY), electing treatment as an S corporation.  JKY operated the            
          merchandise business that was previously operated as a sole                 
          proprietorship.  During 1990 and 1991, petitioners owned                    
          100 percent of the stock of JKY.  By the end of 1995, petitioners           
          closed the store as a result of the downturn in the Mexican                 
          economy and the devalued peso.                                              
               JKY's suppliers, mainly Korean-owned businesses, were                  
          primarily located in Los Angeles, California.  Yoon entertained             




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