Paul Mifsud and Maria G. Mifsud - Page 6




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          Florida.  Around 1989 or 1990, petitioners purchased a house in             
          Hudson, Florida, in which they resided at the time of the trial             
          in this case.                                                               
               Shortly after petitioners moved to Florida, they, together             
          with their daughter Ms. Mamo and her husband Mr. Mamo, organized            
          Paul & Joe, Inc., an S corporation, for the purpose of acquiring            
          and operating Spring Hill Family restaurant (Spring Hill res-               
          taurant).  At all relevant times, petitioners owned in the                  
          aggregate 60 percent, and Ms. Mamo and Mr. Mamo owned in the                
          aggregate 40 percent, of the stock of Paul & Joe, Inc.  Spring              
          Hill restaurant is located near Weehi Wachee Springs, a major               
          Florida tourist attraction.                                                 
               Around 1990, petitioners, together with their daughter Ms.             
          Mamo and her husband Mr. Mamo, organized Nichole & Eric, Inc., an           
          S corporation, for the purpose of operating a restaurant known as           
          Breakfast Club of 7 Hills.  At all relevant times, petitioners              
          owned in the aggregate 50 percent, and Ms. Mamo and Mr. Mamo                
          owned in the aggregate 50 percent, of the stock of Nichole &                
          Eric, Inc.                                                                  
               Around 1991, petitioners, together with their daughter                 
          Geraldine and her husband, organized Crystal & Ryan, Inc., an S             
          corporation, for the purpose of operating a restaurant known as             
          The Breakfast Club.  At all relevant times, petitioners owned in            
          the aggregate 51 percent, and their daughter Geraldine and her              





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