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business of petitioner Zero Gee Enterprises (Zero Gee) was
located in Carson City, Nevada.
In the 1980's, petitioner worked for Hewlett Packard Co.
(HP) and several other computer companies as a computer
programmer. In 1987, petitioner wrote a book called “Taming the
HP 3000”, which described the use and performance of mid-range
and mainframe HP computer systems.
In 1990, petitioner organized as a sole proprietorship a
business to provide consulting services, computer software
development, and UNIX training relating to the HP 3000 Series of
computers. Petitioner was the sole owner of the business, and
the business was operated under the name of Lund Performance
Solutions (LPS).
After several years, petitioner considered selling LPS and
received an offer to purchase LPS for $700,000. Petitioner,
however, rejected the offer because he believed LPS to have a
fair market value of $1 to $2 million.
On May 19, 1993, with assistance from an organization called
Bigelow Charter Corp. (Bigelow Charter), petitioner formed Zero
Gee as a trust, and petitioner purportedly transferred to Zero
Gee his 100-percent ownership interest in LPS in exchange for
100-percent of the beneficial interest in Zero Gee.
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