William A. and Gayle T. Cook, Donors - Page 3




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                                     Background                                       
               Petitioners resided in Bloomington, Indiana, at the time               
          their petition was filed with the Court.                                    
               The following is a summary of the relevant facts.  They are            
          stated solely for the purpose of deciding the pending cross-                
          motions for partial summary judgment, and they are not findings             
          of fact for this case.  See Fed. R. Civ. P. 52(a); Rule 1(a).               
               The Creation of the Trusts                                             
               On June 7, 1993, petitioner William A. Cook (Mr. Cook)                 
          created the William A. Cook 1993 grantor retained annuity trust             
          and transferred 12,600 shares of Class A common stock of Cook               
          Group, Inc., to such trust.  On the same day, petitioner Gayle T.           
          Cook (Mrs. Cook) created the Gayle T. Cook 1993 grantor retained            
          annuity trust and transferred 12,600 shares of Class A common               
          stock of Cook Group, Inc., to such trust.                                   
               On August 30, 1995, Mr. Cook created the William A. Cook               
          1995 grantor retained annuity trust and transferred 14,360 shares           
          of Class A common stock of Cook Group, Inc., effective August 31,           
          1995, to such trust.  On the same day, Mrs. Cook created the                
          Gayle T. Cook 1995 grantor retained annuity trust and transferred           
          11,300 shares of Class A common stock of Cook Group, Inc.,                  
          effective August 31, 1995, to such trust.                                   
               Petitioners were named as cotrustees for each of the GRAT’s.           
          Each GRAT also provides that it is intended to be a grantor                 






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