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through December 31, 1990, Victor, Jr. held resident alien
immigration status with the United States.
During January 1989, Victor, Jr. met Ann Cohen, a resident of
6217-2 Bay Club Drive, Fort Lauderdale, Florida. Victor, Jr. and
Ms. Cohen eventually began dating and were married on August 16,
1991.
During 1990, Victor, Jr. conducted business for Powertex in
Florida by contacting and meeting with its Florida customers.
Victor, Jr. utilized a phone, desk, and fax machine located in Ms.
Cohen's apartment for conducting Powertex business. Victor, Jr.
also utilized an automobile owned by Powertex while in Florida
during 1990. On March 26, 1990, Powertex purchased mobile telephone
service for Victor, Jr.'s use at Ms. Cohen's apartment. During or
around May of 1990, Victor, Jr. transported a boat that he owned
with Stephen from Rouses Point, New York to Fort Lauderdale,
Florida, docking it at the marina servicing Ms. Cohen's apartment.
In the insurance policy covering the boat, Victor, Jr. listed Ms.
Cohen's apartment as his address and the address where the boat is
normally kept.
On August 22, 1990, Victor, Jr. obtained a driver's license
issued by the State of Florida. Again, Ms. Cohen's apartment is
listed as his address. During 1990, Victor, Jr. incurred charges on
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