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tickets in Korean ethnic communities in the United States for
flights between the United States and Korea.
Beginning in 1984, petitioner incorporated six wholly owned
corporations, operating in different localities under the “NA
Tours” name, to conduct his consolidator business (hereinafter in
the aggregate referred to as the NA Tours companies). In August
1984, petitioner incorporated K-P Travel, Inc. (K-P Travel), an
Illinois corporation. In June 1986, petitioner changed K-P
Travel’s name to N.A. Tours, Inc. (IL NA Tours). Its principal
place of business was Chicago, Illinois. In March 1986,
petitioner incorporated NA Tours of California, Inc. (CA NA
Tours), a California corporation, whose principal place of
business was Los Angeles, California. In June 1986, petitioner
incorporated NA Tour of New York, Inc. (NY NA Tours), a New York
corporation, whose principal place of business was New York, New
York. In September 1986, petitioner incorporated NA Tours of San
Francisco, Inc. (SF NA Tours), a California corporation, whose
principal place of business was San Francisco, California. At
some time, petitioner also incorporated NA Tours of Washington,
D.C., whose principal place of business was Washington, D.C., and
NA Tours of Seattle, Washington, whose principal place of
business was Seattle, Washington. From 1986 until the end of
1988, Air America did not operate as a consolidator, but during
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