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the San Francisco area. Yoshinori traveled to Japan and other
places to learn how to operate a sushi bar restaurant and to
investigate and purchase necessary equipment.
In 1988 and 1989, Toraya operated the Post Street restaurant
and the Berkeley restaurant. After June 30, 1989, Toraya
operated only the Post Street restaurant because Toraya closed
the Berkeley restaurant after Junichi, who served as manager of
that restaurant, left the San Francisco area.
On its 1988 return, Toraya claimed $9,733 in office expenses
of which $7,933 purportedly was paid to Motomi to reimburse her
for expenses she incurred in maintaining an office in her home.
On its 1989 return, Toraya claimed $12,000 in office expenses all
of which purportedly was paid to Motomi to reimburse her for
expenses she incurred in maintaining an office in her home.
Junichi is Yoshinori and Akiko's son (and Motomi's brother).
Joan was Junichi's wife during the years 1988 and 1989. They
were subsequently divorced.12 Although Junichi managed the day-
to-day operations of the Berkeley restaurant, Joan handled its
financial affairs (in a manner similar to the way Motomi handled
the financial affairs for the Post Street restaurant). That is,
Junichi would take home the receipts from the restaurant, the
waitress tags, the cash register receipts, and all the charge
tickets, and Joan would reconcile the cash register tape to the
12 At the time of trial, Junichi was living in Hawaii and
Joan in the State of Washington. Junichi and Joan are not
parties in this case.
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