Isaac Baranowicz and Lora D. Baran, f.k.a. Lorraine D. Baranowicz - Page 3

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          petitioners’ son, Lora ceased employment outside the home and               
          became a housewife and mother.  Between 1980 and 1984, Lora also            
          attended college courses pertaining to interior decorating and              
          design.  Lora has no training in finance, tax, accounting, or               
          business.                                                                   
               Early in petitioners’ marriage, petitioner Isaac Baranowicz            
          (Isaac) attended college and earned a bachelor’s degree, master’s           
          degree, and a certified public accountant (C.P.A.) license.  In             
          1968, Isaac began working for an accounting firm in which, by               
          1975, he had become a partner.  In 1978, Isaac formed I.B.                  
          Management, Inc. (the firm), to establish his own accounting and            
          financial planning firm.  Isaac, as sole owner and a board member           
          of the firm, made Lora the secretary of the firm, but Lora’s only           
          responsibility as secretary was to sign the minutes of the firm’s           
          board meetings.                                                             
               During petitioners’ marriage, Isaac handled all family                 
          financial matters.  Because of Isaac’s education and experience,            
          Lora relied on and trusted Isaac to handle properly the family’s            
          finances.  Isaac managed and handled the family’s checkbooks,               
          retirement accounts, and other investments.  When a financial               
          matter required Lora’s signature, Isaac instructed Lora where to            
          sign, and Lora did so without question.                                     
               Through one of Isaac’s clients, Isaac was introduced to                
          certain equipment leasing partnerships.  Isaac invested in                  






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