-4-
agents in Chicago, Illinois, and took estate planning courses
from the New England Life Insurance Co. Mrs. Fox had no training
in tax.
During the years in issue, Mr. and Mrs. Fox owned 15 or 16
rental mobile homes, 2 rental houses, and an apartment building.
Mrs. Fox managed their real estate rental business before and
after they created the trust at issue.
Mike Dunn (Dunn), a certified public accountant, prepared
Mr. and Mrs. Fox's income tax returns from 1986 to the time of
trial.
B. Oxyfresh
Oxyfresh USA, Inc. (Oxyfresh), is a network marketing (also
known as multilevel marketing, described further below) company
which began operating in 1983. Oxyfresh sold personal care, pet
care, nutrition, dental hygiene and skin care products, a quit-
smoking program, and air purifiers.
Mr. Fox sold Oxyfresh products and recruited other people to
sell Oxyfresh products. The distributors Mr. Fox recruited could
also recruit other people to distribute Oxyfresh products.
Mr. Fox engaged in this activity in 1983 and every year
thereafter. He received a commission for selling Oxyfresh
products. He received a smaller commission on sales made by
distributors. In 1992, Mr. Fox traveled 3 weeks per month in the
United States and Canada conducting Oxyfresh training and
motivational seminars. Because of his efforts for Oxyfresh, Mr.
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