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FINDINGS OF FACT3
At the time its petition was filed, petitioner, Taiyo Hawaii
Co., Ltd. (Taiyo Hawaii), had its principal place of business in
Honolulu, Hawaii. Petitioner was a Japanese corporation engaged
in real estate activity in Hawaii. Petitioner was incorporated
on October 30, 1985, with its outstanding capital stock held by
Taiyo Fudosan Kogyo Co. (Fudosan), a Japanese corporation.
Pursuant to an October 31, 1985, merger agreement, Fudosan
transferred its Hawaiian assets to petitioner and its Japanese
assets to another related company.
Fudosan and another Japanese corporation were merged into
the Seiyo Corp. (Seiyo), a Japanese corporation, as of January 1,
1986. As part of the merger, Seiyo acquired (and retained
throughout the years in issue) petitioner's issued and
outstanding capital stock. Seiyo was part of the real estate and
tourism group of a Japanese conglomerate, Seibu Saison Group.
On October 1, 1988, petitioner's assets included: Cash;
certain receivables; a condominium in Waikiki, Hawaii; a 50-
percent interest in a Hawaiian partnership, T-3 Wailea Joint
Venture; and certain unimproved real property on the island of
Hawaii. The Hawaiian realty had been held by petitioner since
1986, having been acquired by Fudosan between 1973 and 1980. One
3 The parties’ stipulation of facts and the attached
exhibits are incorporated by this reference.
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