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salesman and became a sales or division manager, where he learned
to hire and train salesmen to sell cemetery plots in advance of
need. Eventually, petitioner became a sales manager for four
small cemeteries, where he was responsible for all of their sales
in advance of need. Desiring to build his own cemetery
operation, petitioner saved his earnings and
organized/incorporated Resthaven Gardens of Memory, Inc.
(Resthaven), in 1958. During the years at issue, petitioner was
the sole shareholder, president, and chairman of the board of
Resthaven. In 1958, Resthaven entered into certain land option
contracts with petitioner and his then wife, Mary Louise Bledsoe
(Ms. Bledsoe). Together, they held an undivided three-fourths
interest in land adjoining the Resthaven cemetery. Wichita
Developers, Inc., an affiliated corporation, held the remaining
one-fourth interest. The land option contracts granted
petitioner and Ms. Bledsoe an interest in the gross sales of
Resthaven.
In 1979, petitioner filed for divorce from Ms. Bledsoe. The
two owned considerable property during their marriage. In 1981,
petitioner was granted a divorce, and property division was the
principal issue in the divorce proceedings. The divorce decree
granted Ms. Bledsoe the right to receive payments from Resthaven
on the land option contracts which had previously been payable to
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