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worked at the bank for approximately 7 years, advancing from a
mail clerk position to that of a teller and thereafter became an
administrative office manager of a general insurance agency. In
1961, the insurance agency transferred her to Miami, Florida,
where she met her first husband, married, and had a daughter in
1964. Shortly thereafter, petitioner divorced her first husband
and returned to the Royal Bank of Canada for a short time.
Following that, she returned to Florida and began to work for
Amicable Life Insurance Co. (Amicable). Petitioner met Mr.
Martin, a part-time insurance salesman at Amicable, and they were
married in 1968, and petitioner became a full-time housewife with
two additional children born during 1969 and 1973.
Mr. Martin established a very successful insurance agency,
named “Insurance Agency of America” (IAA), which wrote policies
exclusively for Amicable. Generally, petitioner’s involvement
with IAA was in the role of supporting Mr. Martin’s career as his
spouse, entertaining business associates, and accompanying Mr.
Martin on agent recruiting trips.
In September 1981, Mr. Martin formed a Florida corporation
named “Glenn H. Martin and Associates, Inc. d/b/a IAA” and named
himself board chairman, president, and treasurer. Petitioner was
named vice president and secretary of the corporation.
Petitioner was not involved in the business of IAA, and her
designation as an officer of the corporation was in the nature of
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