Jefferry Phuong Vo and Mai Xuan Nguyen - Page 4




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          property.  None of the partners lived in the San Jose property.             
          All three had their own personal residences.                                
               The partners began marketing the generator in 1993, and they           
          continued to use the San Jose property for office space and to              
          demonstrate the generator for potential distributors.  They used            
          a room in the San Jose property as a demonstration area to                  
          display the generator’s capacity to run a television, fan, and              
          several lights.  Petitioner explained that the generator was not            
          designed to supply sufficient energy to run a typical household             
          in the United States but that it was designed to meet the more              
          limited energy needs of households in developing countries.                 
               In 1994 the partners sent a generator to one of the                    
          partner’s relatives in Vietnam who unsuccessfully attempted to              
          sell the system in Vietnam at a price of $2,000.  The relative              
          decided to keep the generator for himself, and the partners gave            
          it to him at their cost of $300.                                            
               After further unsuccessful attempts at establishing                    
          distributors in Vietnam, petitioner bought out his partners’                
          interests for $1,000 on May 30, 1994, and began marketing the               
          generator under the name Solarsys Technology (Solarsys).                    
          Petitioners continued to use the San Jose property and began                
          looking for distributors in other countries such as Malaysia and            
          the Philippines.  In 1995 approximately 12 people expressed an              
          interest in establishing distributorships in their countries, and           






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