Robert A. and Colleen L. Lund - Page 3




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          business of petitioner Zero Gee Enterprises (Zero Gee) was                  
          located in Carson City, Nevada.                                             
               In the 1980's, petitioner worked for Hewlett Packard Co.               
          (HP) and several other computer companies as a computer                     
          programmer.  In 1987, petitioner wrote a book called “Taming the            
          HP 3000”, which described the use and performance of mid-range              
          and mainframe HP computer systems.                                          
               In 1990, petitioner organized as a sole proprietorship a               
          business to provide consulting services, computer software                  
          development, and UNIX training relating to the HP 3000 Series of            
          computers.  Petitioner was the sole owner of the business, and              
          the business was operated under the name of Lund Performance                
          Solutions (LPS).                                                            
               After several years, petitioner considered selling LPS and             
          received an offer to purchase LPS for $700,000.  Petitioner,                
          however, rejected the offer because he believed LPS to have a               
          fair market value of $1 to $2 million.                                      
               On May 19, 1993, with assistance from an organization called           
          Bigelow Charter Corp. (Bigelow Charter), petitioner formed Zero             
          Gee as a trust, and petitioner purportedly transferred to Zero              
          Gee his 100-percent ownership interest in LPS in exchange for               
          100-percent of the beneficial interest in Zero Gee.                         










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