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year in issue, petitioner conducted business under the names "King
Express" and "JRJ Express, Inc." JRJ operated out of 13 U.S.
offices and had some 100 employees. Approximately 78 percent of the
items petitioner delivered to Guatemala contained money orders or
checks from Guatemalans residing in the United States to their
family members back home.
Customers who wished to use petitioner's services could: (1)
Personally visit one of petitioner's offices, fill out the
necessary form, and pay a fee; or (2) put the item, payment, and
accompanying paperwork inside an envelope that was preprinted with
petitioner's post office box address. During the year in issue,
petitioner charged a $12 fee for: (1) Transporting the sender's
envelope from any U.S. location to petitioner's Los Angeles office;
(2) delivering the item to the addressee in Guatemala; and (3)
sending a delivery receipt to the sender.
The Guatemalan Companies
Julio Roberto Fong (J.R. Fong) and Ricardo Alfonso Leon (R.A.
Leon),1 brothers of J.F. Leon living in Guatemala, owned and
controlled several Guatemalan companies (the Guatemalan companies)
that made deliveries of letters, packages, and other items from
Guatemala to the United States. These companies conducted business
1 At the time of trial, J.R. Fong was deceased; R.A. Leon
continued running the Guatemalan businesses.
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