- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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