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manufacturing companies and during this period petitioner became
familiar with plastic injection molding machines. In 1975,
petitioner was hired by Ramsey Winch Co. (Ramsey) as the vice
president of operations. At Ramsey, petitioner acquired
expertise in manufacturing winches. He negotiated Ramsey's
acquisition of the Auto Frame Co., and thereafter was employed as
president of both companies. Petitioner continued his employment
with Ramsey at least through the date of trial.
Neither the educational nor employment histories of Carolyn
J. Henry have been placed in the record. The parties stipulated
that she was a "housewife" during 1982.
Petitioners' Federal income tax returns for the years in
issue and presumably the relevant Forms 1045 were prepared by
William L. Storey (Storey). Petitioners have been clients of
Storey, who was a certified public accountant, since the late
1960's. Storey received a bachelor of science degree in Business
Administration with a major in accounting from the University of
Arkansas. Storey retired in 1989 after practicing as a certified
public accountant for 35 years. While in practice, Storey
provided general financial advice to his clients and specialized
in the preparation of Federal income tax returns and financial
statements.
Between 1970 and 1986, Storey occasionally reviewed tax
shelter investments for his clients. In the fall of 1981, Storey
learned about the Sunbelt Group partnership (Sunbelt) after
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