Dennis E. Pewitt and Kathleen M. Pewitt - Page 4

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          he worked for approximately 8 years.  He also obtained a real               
          estate license, and in 1980 left the police department and began            
          selling real estate.                                                        
               Petitioner's role in the marriage was to care for the home and         
          children.  She took responsibility for the household finances, and          
          Mr. Pewitt was responsible for the family's financial support.              
          Throughout their marriage, petitioners' bank accounts were in joint         
          names.                                                                      
               Financially, the early years of petitioners' marriage were             
          lean and worrisome.  Their financial situation improved when, in            
          1981, Mr. Pewitt went to work for Transamerica Title Insurance Co.          
          as a branch manager.  In 1982, Continental Mortgage offered Mr.             
          Pewitt employment at double his Transamerica Title salary; Mr.              
          Pewitt accepted the offer.                                                  
               Because of the dramatic increase in his salary, Mr. Pewitt             
          believed petitioners needed tax "write-offs"; thus, he consulted            
          Ron W. Colwill, a certified financial planner.  Messrs. Pewitt and          
          Colwill met twice.  The first meeting was a "get acquainted                 
          meeting", at which Messrs. Pewitt and Colwill discussed Media               
          Marketers.  Mr. Colwill clarified certain erroneous information             
          given to Mr. Pewitt by one of Media Marketers' general partners.            
          (Mr. Colwill was the other general partner of Media Marketers.)             
          Mr. Colwill advised Mr. Pewitt to discuss with Mrs. Pewitt the              
          possibility of petitioners' making an investment in Media Marketers         





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