Donald J. and Lillian Joy Miravalle - Page 3

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          resulting from that motion, the stipulation of facts, and the               
          attached exhibits are incorporated herein by this reference.                
               Petitioners resided in Largo, Florida, at the time they                
          filed their petitions in this case.                                         
          Background                                                                  
               Petitioners are husband and wife and have been married since           
          1966.  In 1977 or 1978, petitioners, who were then about 50 years           
          of age, moved from St. Louis, Missouri, to Florida.  During at              
          least the years 1979 through 1986, petitioner Donald J. Miravalle           
          (Mr. Miravalle) was also known as Don King, and petitioner                  
          Lillian Joy Miravalle (Mrs. Miravalle) used her maiden name, Joy            
          Smythe, for business activities.2  During the years 1979 through            
          1986, petitioners were engaged in the manufacture and sale of               
          marine air conditioners which they conducted through a sole                 
          proprietorship known variously as King-Air, King Marine, or King            
          Marine Air Conditioning.                                                    
               In 1979, petitioners rented industrial space comprising                
          about 1,260 square feet from Vincent Morelli for the purpose of             
          building air conditioners for boats.   On November 26, 1982, Mr.            
          Miravalle, using the alias Donald J. King, entered into a 2-year            
          lease for approximately 3,500 square feet of space for the period           
          beginning on January 1, 1983, on behalf of King Marine Air                  



               2  Mrs. Miravalle goes by her middle name Joy, rather than             
          her first name Lillian.                                                     




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