Andrew Wesley Frank & Joy Mary Frank - Page 3

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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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