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petitioner and intervenor Rang Sun Park Ishizaki (Mrs. Ishizaki)
were married. Following their marriage, Mrs. Ishizaki joined
petitioner in operating his company, which in about 1989 or 1990
began doing business under the name of Stone Collection. Stone
Collection, in turn, was succeeded in 1994 by Privilege House,
Inc. Both petitioner and Mrs. Ishizaki were employed by
Privilege House during 1995, the year at issue.
The respective roles played by petitioner and Mrs. Ishizaki
in the operation of Stone Collection and Privilege House can be
broadly described as follows. Petitioner was primarily
responsible for sales management and for research and
development. Mrs. Ishizaki’s principal responsibilities focused
on financial matters, production scheduling, and office
management.
Revenues at Privilege House were generated though the sale
to customers of home furnishing items manufactured by the
company. Petitioner, in his research and development capacity,
worked to design styles that would appeal to customers. For
those items selected to be offered to customers, Mrs. Ishizaki
created a price list enumerating the intended selling prices.
Petitioner then worked with commissioned salespersons to finalize
sales to customers. The salespersons would introduce petitioner
to potential buyers as representing Privilege House, and
petitioner would negotiate the final sales price. Petitioner had
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