Domer L. Ishler - Page 5

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               TCM sold electronic components provided by manufacturers, or           
          by intermediaries such as Nissei Sangyo America, Ltd. (NSA), to             
          manufacturers such as Chrysler.  TCM earned commissions on its              
          B.   Other Business Entities                                                
               1.   NSA                                                               
               NSA is an Illinois corporation and subsidiary of Hitachi.              
          It supplied electronic and mechanical components to car                     
          manufacturers during the years in issue.                                    
               2.   Camaro                                                            
               Camaro was incorporated by Philip Lawrence Choy (Choy) under           
          the laws of Hong Kong on July 19, 1983.  Choy was Camaro’s                  
          management nominee.3  Camaro opened a Hong Kong dollar-denominated          
          checking account and a U.S. dollar-denominated savings account at           
          the Hongkong & Shanghai Banking Corp., Ltd. (HSBC), in Hong Kong            
          in July 1983.  Petitioner’s initial contact with Camaro was in              
          1983, through his friend, Richard Adler, whose common law wife,             
          Kay Adler (also known as Jo Ying Ying or Kay Chou), was one of              

               3  Kay Chou and her brother-in-law Chen paid Choy, a                   
          registered agent in Hong Kong, to incorporate Camaro, using                 
          nominee companies as Camaro’s shareholders.  He substituted the             
          names of the shareholders in the corporate charter.  Camaro was             
          ready for business the next day.  The names of Chou and Chen do             
          not appear in Camaro’s records because Camaro’s shareholders were           
          nominee companies.  Choy was not an officer of Camaro.                      

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