Stephen D. Podd - Page 3

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          resident alien status to petitioner on July 7, 1987, which                  
          petitioner held through December 31, 1990.                                  
               During 1990, petitioner owned 24 percent of the outstanding            
          shares of the following corporations:  Powertex, Inc. (Powertex),           
          a Vermont corporation, Powertex Plus, Inc. (Powertex Plus), a               
          Montreal corporation, and Powertex, Inc. (Powertex, S.C.), a                
          South Carolina corporation.  During 1990, petitioner was vice               
          president of Powertex, Powertex Plus, and Powertex, S.C.  As vice           
          president of Powertex, petitioner purchased raw materials and               
          hired employees for the Powertex plant in Alburg, Vermont, and              
          dealt with Powertex customers.  As vice president of Powertex               
          Plus, petitioner oversaw the daily operation of Powertex Plus'              
          factory in Rouses Point, New York, and communicated with Powertex           
          Plus' suppliers in Montreal.  As vice president of Powertex,                
          S.C., petitioner supervised the startup of the company's                    
          operations in Charleston, South Carolina.                                   
               During 1990, petitioner also owned a 25-percent share in the           
          Podd Trust Associates partnership and the Fort Montgomery Estates           
          partnership.  Both partnerships own and lease property in the               
          United States.                                                              
               On January 1, 1989, petitioner met Ann Cohen (Ms. Cohen), a            
          resident of Fort Lauderdale, Florida.  Shortly afterwards,                  
          petitioner and Ms. Cohen began dating.  Petitioner and Ms. Cohen            
          continued dating throughout 1989 and 1990.                                  





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