Ruthe G. Ohrman - Page 5

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          Mr. Ohrman’s Early Withdrawals From His Retirement Account                  
               During 1999, Mr. Ohrman was the owner of an individual                 
          retirement account (IRA) at Dean Witter Reynolds (Dean Witter               
          account).  The Dean Witter account was a rollover account set up            
          by petitioner and Mr. Ohrman in 1997.  Petitioner was present               
          with Mr. Ohrman when the Dean Witter account was established.               
          Thereafter, petitioner maintained a file for the Dean Witter                
          account and placed the monthly account statements into a                    
          notebook.  As of February 28, 1999, the Dean Witter account had a           
          total asset value of $454,406.                                              
               Petitioner was the designated beneficiary of the Dean Witter           
          account, but her written consent was not required to make an                
          early withdrawal.  Petitioner was aware of how much money was in            
          the Dean Witter account in 1998 and 1999, and she believed there            
          was approximately $700,000 in the account at one point in 1998.             
          Because of the size of the Dean Witter account, petitioner                  
          solicited promises from Mr. Ohrman before and during 1999 that he           
          would not use any of the funds in the Dean Witter account for               
               Despite his promises to petitioner, Mr. Ohrman withdrew                
          $79,000 in early distributions from the Dean Witter account in              
          11 separate transactions from March 19 to December 21, 1999, to             
          fund his gambling addiction.  Petitioner neither knew about nor             
          consented to these early distributions, nor did petitioner sign             

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