Jung Sik Lim & Bok S. Lim - Page 3

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          Liquors”.  Petitioners acquired 75 percent and the sister-in-law            
          the remaining 25 percent of Volm’s shares of stock.                         
               After the purchases of the realty and corporate stock,                 
          Volm’s continued to use the ground floor of the Branch building             
          to operate a liquor store.  Petitioners, in addition to being the           
          majority owners of the liquor business, devoted the majority of             
          their time to the operation of the Branch building liquor store             
          business.  Petitioners and the sister-in-law used part of the               
          second floor of the Branch building as their personal residence.            
          The first floor of the Branch building, which is 2,640 square               
          feet, is slightly larger than the second floor, which is 2,160              
          square feet.  Volm’s also used a 286-square-foot office on the              
          second floor of the building.  Overall, 61 percent of the Branch            
          building is used by Volm’s to operate the liquor store, and 39              
          percent is used by petitioners and relatives as their personal              
          residence.                                                                  
               During 1993, the liquor store business did not make rental             
          payments directly to petitioners for the business' use of the               
          Branch property.  Although there was no written lease, the liquor           
          store business paid certain expenses incurred in connection with            
          the Branch property in exchange for its use of the building.                
          Volm’s paid the real estate taxes on the Branch property of                 
          $4,384.45 during 1993.  Volm’s also paid all of the utilities,              
          including the electric, gas, and sanitation costs, incurred for             





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