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Costa Rica. In 1984, while living in Costa Rica, petitioner
started a business, Heart Interface (Heart), to manufacture and
sell electronic and solar powered equipment. Shortly thereafter,
Heart was incorporated in, and petitioner moved to, Washington
State.
From 1984 through 1990, petitioner was president and part-
owner of Heart. In 1988, petitioner decided that he wished to
end his involvement with Heart and move back to Costa Rica.
Thereafter, in 1988, petitioner signed a contract with Valley
Forge Corp. to sell his interest in, and phase out his employment
with, Heart. The sale was completed in March 1990. Heart
continued to employ petitioner until sometime in 1991. For the
years 1988 through 1991, petitioner earned $105,632, $104,325,
$96,269, and $20,453, respectively, as an employee of Heart.
Playa de los Vivos
Having determined that he would return to Costa Rica,
petitioner considered how he would earn a living there. In 1988,
petitioner purchased an approximately 29-hectare improved tract
of bayfront real property in Puntarenas, Costa Rica. Located on
the property was a hotel with five rooms, a kitchen, a
restaurant, and a swimming pool. In 1989, petitioner purchased
approximately 10 additional, adjoining hectares. Petitioner
named the 39 hectares "Playa de los Vivos" and, since 1988, has
operated a resort on the property (the resort or Playa de los
Vivos). Petitioner kept computers and electronic equipment in
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