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incorporated herein by this reference. Petitioners were married
in 1955. At the time they filed the petition, petitioners
resided in Laguna Niguel, California.
A. Petitioners’ Work History
Petitioner-husband (petitioner) began work in the insurance
business in 1957 or 1958 for Penn Mutual Insurance Co. (Penn
Mutual). Except for 2 years with a different insurance company,
petitioner was continuously employed by Penn Mutual until 1979.
In or about 1960, petitioner opened a Penn Mutual agency in
Orange County, California. Petitioner trained agents, and the
agency grew to employ approximately 40-50 people. In 1979,
petitioner earned approximately $75,000. In 1979 or 1980,
petitioner sold the agency to focus on real estate development
activities.
Beginning in 1955, petitioner-wife was employed as a school
teacher. She retired from teaching when her husband’s commercial
real estate development activities became successful.
B. Petitioner’s Real Estate Development Activities
Petitioner entered into commercial real estate development
beginning in 1963 or 1964. Initially, petitioner was successful
with these activities. He sold his first building at a profit,
and he was able to secure tenants, including his employer Penn
Mutual, for the buildings.
In 1978, petitioners formed the H & H partnership with Grant
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