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California to such places as Idaho and Hawaii and eventually
expanded on an international level.
On December 31, 1986, Terry entered into an agreement with
Academy for the sale of his clients' names, records, and
accounts, including the managing general agent's agreements. At
the same time, he entered into a 5-year employment contract with
Academy, commencing on January 1, 1987, to be Academy's executive
vice president--marketing and the chairman of the board of
Academy Services, Inc. During Terry's employment term, Academy
could not require him to relocate. In light of Academy's
business interests around the world, Terry's job focused on
clients in and outside California. As a result, he traveled
outside California regularly.
On August 1, 1988, the Corporation was liquidated, and Terry
made a section 333 election. Before the Corporation was
liquidated, petitioners held a meeting with their tax attorney
and accountant.
Mary Street
In 1973, petitioners purchased property at 2320 Mary Street
(Mary Street) in Riverside, California from Joyce's parents.
Mary Street had been Joyce's family home. Petitioners moved into
Mary Street, and they raised their children there from 1973 until
1980.
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