Anand K. Verma - Page 3




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          A.   Pre-Incorporation Activities                                           
               During 1996 and 1997, petitioner worked for the District of            
          Columbia government as an unemployment compensation claims                  
          examiner.  In an effort to increase his income, petitioner                  
          started a business in the living room of his 880-square-foot,               
          one-bedroom apartment in Silver Spring, Maryland.  The purpose of           
          the business was to sell American manufactured products abroad.             
          Petitioner contacted business counselors in Hong Kong and India             
          for advice in an effort to energize his business.  A business               
          counselor advised petitioner to incorporate to add credibility to           
          his business.  Petitioner was unsuccessful in his sales efforts             
          in 1996.                                                                    
          B.   Post-Incorporation Activities                                          
               On October 4, 1996, petitioner incorporated his business in            
          Maryland under the name Export USA, Inc. (Export).  According to            
          the articles of incorporation, the corporate purpose was to “sell           
          U.S. products abroad and towards that end, to negotiate price and           
          enter into purchase agreements with manufacturers and                       
          distributors.”  Export’s address was petitioner’s apartment in              
          Silver Spring, Maryland.  Petitioner was listed as the director             
          of Export.                                                                  
               Petitioner held himself out to the public as the president             
          of Export.  Petitioner, on Export’s letterhead, corresponded with           
          various sellers and buyers in China, India, Indonesia, the                  






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