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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioners
Petitioners are married and lived in Vallejo, California,
when they filed their petition.
Petitioner Andrew Wesley Frank (Mr. Frank) has a bachelor of
science degree in mechanical engineering and worked as a nuclear
engineer at the Mare Island Naval Shipyard during the years in
issue (1991 and 1992). Petitioner Joy Mary Frank was a homemaker
and beauty consultant during the years in issue. Earl W. Frank
is Mr. Frank's brother.
On their 1991 and 1992 tax returns, petitioners reported
income and expenses from selling living trusts and food
supplements, renting residential property, and leasing an
airplane.
B. Advertising Expenses for Living Trusts
Petitioners began to sell living trusts in 1990. For
purposes of the living trust activity, Mr. Frank advertised that
he was a financial consultant for tax and estate planning
purposes. Petitioners had printed at a date not specified in the
record about 200 brochures which promoted the trusts. Mr. Frank
distributed the brochures at work, church, and at other places to
solicit business. Mr. Frank met with about 10 people per month
who were interested in establishing a trust.
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Last modified: May 25, 2011