Robert E. Iles and Monica M. Iles - Page 18

                                        -18-                                          

          Declaration of Trust states that the Riago Trust was created for            
          the benefit of petitioners and their daughters, Adria and Margo.            
          (The word "Riago" is coined from the last letters of petitioners'           
          daughters' names.) Petitioners were the trustees of the Riago               
          Trust.  The Riago Trust was revocable by the grantors jointly, or           
          by the surviving grantor.  Petitioners, as grantors, had the                
          power, at any time, to withdraw any portion of the net income or            
          principal of the trust.                                                     
               Petitioners conveyed all of their real, personal, and                  
          business property to the Riago Trust, including the following:              
          Their residence; life insurance death benefits; jewelry;                    
          household furnishings; stock or proprietary interests in                    
          Associates (also discussed supra item B), Green, Inc., Random               
          Processing Services, Inc., Consultants (also discussed supra item           
          B), Robert Iles Computer Services, Inc., SSI (also discussed                
          supra item C), and SSC (also discussed supra item C); and "Any              
          and all other business endeavors."  Before and after they                   
          conveyed their property to the Riago Trust, petitioners lived in            
          the same house in Cincinnati.  By letter dated August 18, 1982,             
          Monica, as cotrustee, informed Robert, as cotrustee, that the               
          Riago Trust's assets include a 1980 Rolls Royce, new residential            
          rental property, office furniture and equipment, a 76-percent               
          interest in the Rise Trust, a Saberliner Jet, jewelry,                      
          improvements on their home, and miscellaneous household                     





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