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Court Rules of Practice and Procedure.
For convenience and clarity, we have combined our findings of
fact and opinion with respect to each issue. Some of the facts
have been stipulated and are so found. The stipulation of facts
and the attached exhibits are incorporated herein by this
reference.
General Findings
Petitioners, husband and wife, resided in Milpitas,
California, at the time they filed their petition. Petitioners
timely filed a joint Federal income tax return for 1989, the year
under consideration. They filed an amended return for 1989 on
April 15, 1992.
Petitioner wife, Grace Yei, has a bachelor's degree from
Taiwan University and a master's degree in business administration
from Golden Gate University. She passed the written portion of the
C.P.A. examination following completion of her course work at
Golden Gate University but did not pursue certification.
Petitioner husband, Santar Yei, completed 4 years of college
in Taipei, Taiwan, majoring in mathematics. He obtained a master's
degree in computer engineering from San Jose State University.
Mr. Yei worked for Solectron, located in San Jose, California,
while obtaining his master's degree. In 1979, he purchased 10,000
shares of Solectron stock from that company for $10,000 with money
from his father. In 1989, he tendered 19,998 shares of Solectron
stock to Solectron (pursuant to Solectron's offer to purchase) and
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