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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, the first supplemental stipulation of
facts, the second supplemental stipulation of facts, and the
exhibits attached thereto are incorporated herein by this
reference. Petitioner Chen C. Wang (petitioner) and his wife,
petitioner Victoria R. Wang, resided in Woodside, California, at
the time their petitions were filed. At the time its petitions
were filed, the principal place of business for EIC was located
in Redwood City, California.
Petitioner moved to the United States from Taiwan nearly 40
years ago. He has a degree in electrical engineering from San
Jose State University and a Masters in Business Administration
from the University of California at Berkeley. After completing
his education, petitioner went to work for IBM. While at IBM,
petitioner investigated ways to increase his income, and he
ultimately decided that the best way to make money was to invest
in real estate. Thereafter, petitioner began investing in real
estate, eventually leaving IBM to devote more of his time and
energy to increasing his real estate business. In 1982, peti-
tioner incorporated EIC and used it as the vehicle to effectuate
his real estate investment strategy. Nevertheless, occasionally
petitioner personally purchased and sold land for his own
account.
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