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Petitioner’s affiliation with the San Antonio firm of Soules
& Wallace continued until 1997, when he became self-employed
again and resumed practicing law in Houston. In November 1997,
petitioner purchased a new SEP plan from Southern Farm Bureau.
Some time thereafter, he became associated as “Of Counsel” with
the law firm of Wickliff & Hall, P.C., in Houston. He was
employed there during the year at issue, 1999.
In addition to planning for retirement, a principal factor
that influenced petitioner’s financial decisions was the
education of his daughter, Andrea. Initially, through her
experience with horses on petitioners’ ranch, Andrea had intended
to enroll at Texas A&M University. However, she was also an
accomplished flutist at an early age. While attending the High
School for Performing and Visual Arts (HSPVA) in Houston, she
decided to pursue musical rather than agricultural endeavors.
Petitioner accompanied Andrea to auditions at various
conservatories, including Julliard in New York City, Oberlin
College in Ohio, Curtis Institute in Philadelphia, and the
Eastman School of Music (Eastman) in Rochester, New York.
Travel, private instruction, and other expenses were incurred in
connection with these auditions. Andrea was accepted and decided
to enroll in Eastman.
Petitioner realized that Andrea’s musical studies would cost
significantly more than a Texas A&M degree, which he had
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