Anthony J. and Denise D. Sadberry - Page 6

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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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