David W. Chiu - Page 3

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            attached exhibits.  At the time of filing the petition,                                      
            petitioner resided in San Gabriel, California.                                               
                  Petitioner was born in China in 1950 and came to the United                            
            States in 1970.  Petitioner received a bachelor of science degree                            
            in engineering in the United States and, after graduation, took                              
            graduate courses in business and corporate finance.                                          
                  In 1986, petitioner commenced employment with Varian                                   
            Associates, Inc. (Varian), in Palo Alto, California.                                         
            Petitioner's 1990 Federal income tax return correctly lists his                              
            W-2 wage income for the 1990 taxable year from Varian as $35,181,                            
            from which amounts were withheld for Federal income tax purposes.                            
                  In the fall of 1990, petitioner moved from San Francisco to                            
            Los Angeles where he remained for approximately 3 weeks before                               
            moving to Hong Kong.  Petitioner arrived in Hong Kong on November                            
            28, 1990.  Petitioner did not move to Hong Kong in connection                                
            with a job transfer or to accept new employment and did not                                  
            become an employee of any business while in Hong Kong.  At the                               
            time petitioner moved to Hong Kong, he intended to start a                                   
            business of his own, although he did not have specific plans to                              
            start any particular business.  On his 1990 Federal income tax                               
            return, petitioner claimed a deduction for moving expenses in                                
            connection with the moves to Los Angeles and to Hong Kong in the                             
            amount of $3,184, of which $500 was estimated as the cost of his                             
            move to Los Angeles.                                                                         

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