Charles F. Sutter and Cheryl Sutter - Page 2

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          respectively.  The issue for decision is whether petitioners                
          realized and must recognize income upon obtaining coverage under            
          certain life insurance policies during the years in issue.                  
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          Petitioners are husband and wife.  They filed timely joint                  
          Federal income tax returns for the years 1991 and 1992.  At the             
          time the petition was filed, they resided in Afton, Wyoming.                
               Charles Sutter was employed as a police officer by the City            
          of Santa Monica, California, from 1963 until 1969.  He was next             
          employed as a police officer by the City of Afton, Wyoming, from            
          1969 until 1981.  After leaving the Afton police force in 1981,             
          he began to work for Valley Lumber, a sawmill and lumber company            
          that was owned by Arthur Schwab.                                            
               Arthur Schwab is the father of Marvin Schwab.  Marvin Schwab           
          is the father of Daniel Schwab, Vance Schwab, and Lee Schwab.               
          Charles Sutter first met the Schwabs in 1969 or 1970, when he was           
          purchasing building materials to remodel his house.  During the             
          relevant periods, Marvin Schwab, Vance Schwab, and Daniel Schwab            
          were licensed life insurance salesmen in the State of Wyoming.              
          They were associated with the Daniel Schwab Agency, which was               
          located in Afton, Wyoming.  Although Lee Schwab maintained an               
          office in the same building where the offices of the Daniel                 







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