Estate of Wayne C. Bongard, Deceased, James A. Bernards, Personal Representative - Page 4

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          representative of decedent’s estate.  At the time the petition              
          was filed, Mr. Bernards resided in Minnesota.  On February 4,               
          2003, respondent issued a notice of deficiency to the estate with           
          respect to its timely filed Form 706, United States Estate (and             
          Generation-Skipping Transfer) Tax Return.                                   
          I.  General Background and Time Line                                        
               Decedent was a skilled and experienced businessman.  In                
          1966, decedent was a founding employee of Fluoroware, Inc.                  
          (Fluoroware), a Minnesota corporation that produced packaging               
          materials for the semiconductor, data storage, and                          
          microelectronic industries.  In 1980, decedent left Fluoroware to           
          start his own corporation, Empak.                                           
               On November 9, 1984, decedent married Cynthia Bongard.                 
          Decedent entered into this marriage with four children from a               
          prior marriage: Beth Akerberg, Mark Bongard, Rhonda Notermann,              
          and Lynn Zupan.  Cynthia Bongard also entered the marriage with a           
          child from a previous marriage, Terra Saxe.2  Decedent and                  
          Cynthia Bongard never had any children together, nor did decedent           
          adopt Terra Saxe.                                                           
               On May 23, 1986, decedent formed the Wayne C. Bongard                  
          Irrevocable Stock Accumulation Trust (ISA Trust) for the benefit            



               2The parties stipulated that Terra is the correct spelling,            
          but the Wayne C. Bongard Irrevocable Stock Accumulation Trust               
          Agreement spells her name Tara.                                             





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