Charles F. Sutter and Cheryl Sutter - Page 3

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          Schwab Agency were located, he was not directly involved with               
          that agency.                                                                
               Charles Sutter purchased life insurance through Marvin                 
          Schwab before the years in issue.  Although the extent of the               
          coverage is not exactly clear from the record, it appears that              
          before 1991, he generally maintained between $25,000 and $50,000            
          of life insurance.  In 1991, Marvin Schwab approached Charles               
          Sutter and suggested that he purchase a certain type of life                
          insurance policy offered by the Royal Maccabees Life Insurance              
          Co. (the Royal policy).  At the time, Charles Sutter was employed           
          by Aviat, Inc., and Christen Industries, Inc.  His wages totaled            
          $16,803.54 for that year.                                                   
               The Royal policy was described as a flexible premium                   
          adjustable life insurance policy providing death benefits in the            
          amount of $250,000.  The first-year premium for the Royal policy            
          was $7,177.  On direct examination petitioner testified as                  
          follows with respect to the payment of the first-year premium due           
          on the Royal policy:                                                        
                    Q. Do you recall how he - - how you would pay for                 
               the policy?                                                            
                    A. Yes.                                                           
                    Q. How was that?                                                  
                    A. He [Marvin Schwab] said he would give me the                   
               premium, and I would write back to * * * [Royal                        
               Maccabees Life Insurance Co.].                                         






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