Betsy O. Muhn - Page 4

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          PFA since its inception. No trust certificates have ever been               
          received by any of PFA's named beneficiaries.                               
               Petitioner has never met Mr. Bates or Mr. Smith, nor does she          
          have any knowledge of Peer Financial Group or First Surety Bank.            
          Petitioner was not involved in the operation of PFA, although she           
          executed a number of documents relating to the trust at the                 
          direction of her husband.                                                   
               In June 1989, petitioner and her husband conveyed title to             
          both their residence and a cabin (each of which was subject to a            
          preexisting mortgage) to PFA.  PFA did not assume the obligation            
          under either of the mortgages.  After the transfer, petitioner and          
          her husband continued to reside in the house transferred to PFA;            
          their son lived in the cabin.  Neither petitioner, her husband, nor         
          their son paid rent to PFA.                                                 
               On June 21, 1989, PFA (by or through Mr. Muhn and Scott Muhn           
          acting as PFA trustees) purchased Quick Print Express, a printing           
          business, for approximately $80,000.  Mr. Muhn and Scott Muhn paid          
          the sellers approximately $30,000 as a downpayment; the $50,000             
          balance was payable in 120 monthly installments of $660.75 each.            
          Mr. Muhn and Scott Muhn obtained financing for this acquisition by          
          listing as their assets the real property transferred to PFA by             
          petitioner  and  her  husband.  (Petitioner  believed  she  was             
          transferring her interest in her home and cabin to the trust in             
          order to assist her son in obtaining financing for the printing             





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