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incorporated herein by this reference. Petitioners resided in
Weed, California, on the dates the petitions were filed in these
cases.
I. Petitioners and Their Investment
Petitioner husband (Mr. Hitchen) was raised in England,
where he left school around the age of 14. Mr. Hitchen worked at
various jobs and then served in the military for 5 years.
Petitioners were married in 1953, and they came to the United
States in 1956. Mr. Hitchen began working at General Mills in
Lodi, California, in 1958, and he continued working there through
the years in issue. Mr. Hitchen earned wage income of $45,353 in
1984, $47,746 in 1985, $51,797 in 1986, $50,574 in 1987, $50,004
in 1988, and $57,076 in 1989. Petitioner wife (Ms. Hitchen)
worked in an office prior to coming to the United States in 1956,
but she has not worked outside the home since that time.
In the latter part of 1986, Mr. Hitchen learned that several
of his co-workers at General Mills were involved in investments
promoted by Mr. Hoyt. At that time, Mr. Hoyt was paying
approximately $50 per investor as an incentive for current
investors to bring in new investors. Mr. Hitchen asked his co-
workers about the investment, and petitioners then decided to
look into making an investment themselves.
Petitioners attended several investment meetings together.
Following these meetings, petitioners decided to invest in one of
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