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years in issue, petitioner owned a one-third interest, his wife
owned a one-third interest, and they jointly owned a one-third
interest in the Garrahan Agency.
Travelers authorized the Garrahan Agency to solicit
applications or proposals for insurance on behalf of Travelers in
1969. Travelers authorized the Garrahan Agency to solicit life
insurance contracts for Travelers during the years in issue.
C. Framingham Union Hospital, Inc.
During the years in issue, Framingham Union Hospital, Inc.
(FUH), was a not-for-profit hospital in Framingham,
Massachusetts. Petitioner's father-in-law had been involved with
hospital activities since the 1940's or 1950's.
Petitioner began his association with FUH in the late 1960's
or early 1970's at the encouragement of his father-in-law.
Petitioner initially helped FUH with fundraising. He became a
member of the executive committee of FUH in the early 1970's.
Petitioner was a vice president of FUH from 1979 to 1982. In
1982, he was a member of FUH's board of trustees, executive
committee, and finance committee.
The board of trustees made policy for FUH, and the executive
committee implemented it. FUH had 18 to 22 trustees in 1981-82.
Salaried officers of FUH reported to its executive committee and
attended executive committee meetings. FUH committees reported
to the executive committee. James Walckner (Walckner) was chief
executive officer and executive vice president of FUH when
petitioner became a trustee.
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