David D. Le, a.k.a. David Dung Le, a.k.a. Dung V. Le and Kim Huong Le, a.k.a. Kim Le, et al. - Page 6

                                         -6-                                          
          II                                                                          
                    The purpose of this corporation is to engage in                   
               the profession of Medicine and any other lawful                        
               activities (other than the banking or trust company                    
               business) not prohibited to a Corporation engaging in                  
               such profession by applicable laws and regulations.                    
          III                                                                         
                    This Corporation is a Professional Corporation                    
               within the meaning of Part 4 of Division 3 of Title 1                  
               of the California Corporations Code.                                   
          IV                                                                          
                    The name in the State of California of this                       
               Corporation’s initial agent for service of process is                  
               DUNG VAN LE, 4614 EL CAJON BOULEVARD, SUITE 7, SAN                     
               DIEGO, CALIFORNIA 92115.                                               
          At or about that time, California assigned to the corporation a             
          corporate number.  Five months later, in May 1983, the                      
          corporation applied for and received a Federal employer                     
          identification number.                                                      
               Petitioner incorporated his medical practice in order to               
          save taxes.  He was the corporation’s sole shareholder, sole                
          director, sole officer, and sole physician.  His corporate                  
          business began in San Diego, California, and it moved to Orange             
          County, California (Orange County), in or about 1989.                       
               During the subject years, petitioner called himself David              
          Dung Le, he operated his corporation under the name DDL, and he             
          personally performed all of DDL’s medical services.  During those           
          years, DDL had an active business checking account that had been            
          opened at a bank in Orange County contemporaneously with                    





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