Charles F. Sutter and Cheryl Sutter - Page 2
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respectively. The issue for decision is whether petitioners
realized and must recognize income upon obtaining coverage under
certain life insurance policies during the years in issue.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioners are husband and wife. They filed timely joint
Federal income tax returns for the years 1991 and 1992. At the
time the petition was filed, they resided in Afton, Wyoming.
Charles Sutter was employed as a police officer by the City
of Santa Monica, California, from 1963 until 1969. He was next
employed as a police officer by the City of Afton, Wyoming, from
1969 until 1981. After leaving the Afton police force in 1981,
he began to work for Valley Lumber, a sawmill and lumber company
that was owned by Arthur Schwab.
Arthur Schwab is the father of Marvin Schwab. Marvin Schwab
is the father of Daniel Schwab, Vance Schwab, and Lee Schwab.
Charles Sutter first met the Schwabs in 1969 or 1970, when he was
purchasing building materials to remodel his house. During the
relevant periods, Marvin Schwab, Vance Schwab, and Daniel Schwab
were licensed life insurance salesmen in the State of Wyoming.
They were associated with the Daniel Schwab Agency, which was
located in Afton, Wyoming. Although Lee Schwab maintained an
office in the same building where the offices of the Daniel
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