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times, petitioner also had a long-time secretary and
administrative assistant, Patsy D. Permenter (Permenter), who was
also an adult at such times and not otherwise related to
petitioner.
Petitioner, acting through a revocable trust of which he and
Permenter were trustees, entered into agreements entitled Joint
Purchases of Life Estates and Remainder Interests pursuant to
which the parties would identify securities to be acquired in
which petitioner would have a life estate and the other parties
would have interests as indicated by the following:
(1) May 1, 1989, agreement - remainder interests in
Meredith and Nancy;
(2) June 19, 1989, agreement - remainder interest in Nancy;
(3) October 31, 1989, agreement - secondary life interest
in Nancy and remainder interest in Permenter;
(4) June 15, 1990, agreement - secondary life interest in
Nancy and remainder interest in Permenter.
All of the agreements provided that the parties would
identify securities for joint investment by executing an agreed
form designated by the parties as Exhibit A, that each would pay
a proportionate share of the purchase price of the joint
investments and that the disposition of any such investments
could be made only upon the direction of all parties.
The bonds purchased were tax-exempt bonds and were acquired
from unknown third parties through Prudential Bache Securities
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