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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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