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(Kumiko Talmage) moved to Ikuta, Japan, where petitioner
temporarily worked at a language school. Petitioner and Kumiko
Talmage (Talmages) have three children: Lisa Talmage Allen, born
in 1976, Korianton Edward Talmage (Kory Talmage), born in 1978,
and Lillian Talmage, born in 1984.
Beginning in January 1979, petitioner was employed in Japan
to work on various real estate developments and investments and
to provide investment advisory services.
In May 1990, the Talmages purchased a vacation home in Black
Butte, Oregon (Black Butte property), for $145,000. In June
1990, the Talmages also purchased, as a rental property, a home
in Vancouver, Washington (Vancouver property), for $101,900.
On November 17, 1997, the Talmages purchased 47.73 acres of
property for $903,000 at 35701 NE Chamberlain RD, Corbett,
Multnomah County, Oregon (Rivercliff property), to develop into a
permanent residence and farm. At the closing, the Talmages paid
$383,967 in cash as a downpayment and gave the seller a
promissory note for $519,033 with a trust deed on the Rivercliff
property to secure the unpaid balance. In February 1998,
petitioner paid the balance owing on the $519,033 promissory note
with funds wire transferred by New Century Properties Limited
(NCPL).3 Petitioner did not report the $519,033 as income on his
3 NCPL is a British Virgin Islands registered corporation
organized on Feb. 28, 1991, with authorized capital of $50,000.
(continued...)
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