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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of facts and attached exhibits are incorporated
herein by this reference. Petitioner resided in the State of
Washington at the time the petition was filed.
Background
Petitioner and Thomas J. Dillon were married in 1963.
During the marriage petitioner gave birth to two sons, Mark and
Chris Dillon. The Dillons separated in 1984 and subsequently
were divorced in 1987. Petitioner and Thomas Dillon filed joint
Federal income tax returns for both 1981 and 1982.
Petitioner has a high school degree and completed one year
of college at Brigham Young University. In addition, she has
attended cosmetology school. Petitioner worked as a hairdresser
the first year that she and Thomas Dillon were married. After
the first child was born, however, petitioner stopped working as
a hairdresser and stayed at home as a homemaker for the remainder
of the marriage.
Mr. Dillon formed Dillon Securities, Inc., in the early
1970s. Dillon Securities, Inc. (Dillon Securities), is a corpo-
ration engaged in the stock brokerage business, specializing in
small-cap, speculative stocks. During the years at issue, Thomas
Dillon was a director, officer, and the sole shareholder of
Dillon Securities. Additionally, Mr. Dillon, working as a trader
for Dillon Securities, was actively involved in the stock trading
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