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FINDINGS OF FACT
Some facts have been stipulated and are so found. The
stipulation of facts, first supplemental stipulation of facts,
second supplemental stipulation of facts, and attached exhibits
are incorporated herein by this reference. Petitioner resided in
Lincolnwood, Illinois, when he filed the petition in this case.
Petitioner’s Retail Travel and Consolidator Activities
In 1981, petitioner, who also is known as Kee Soo Han,
incorporated Air America Travel Services, Inc. (Air America), an
Illinois corporation, the principal place of business of which
was in Chicago, Illinois. At all times, petitioner was Air
America’s sole shareholder. Air America sold airline tickets to
the general public as a retail travel agent. During 1984, Air
America also started doing business as a consolidator2 for
Northwest Airlines, Inc. (Northwest).3 Air America’s
consolidator activities primarily involved selling airline
2 A consolidator is a third-party seller of airline tickets
written on blank tickets imprinted with the airline carrier’s
name, called ticket stock, issued by an airline carrier. The
consolidator sells the ticket stock wholesale to retail travel
agents, called subagents, at a price lower than the price at
which retail travel agencies usually sell airline tickets to the
general public.
3 For some of the relevant period, Northwest Airlines, Inc.,
operated under the name “Northwest Orient Airlines”.
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Last modified: May 25, 2011