Sylvia Osterbauer and Estate of Joseph Osterbauer, Deceased, Sylvia Osterbauer, Personal Representative - Page 3

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               Decedent, during his lifetime, worked primarily in the real            
          estate business.  Decedent was involved in subdividing and                  
          developing real estate, as well as building and purchasing                  
          residential rental property.  Petitioner testified that                     
          decedent's interests were broad based, and, at various times in             
          his life, he was also a farmer and held an interest in an oil               
          well and a gold mining claim.  Petitioner presented no evidence,            
          except for her own self-serving testimony, that would indicate              
          the exact breadth of decedent's various interests outside the               
          scope of his general real estate business.                                  
               Petitioner spent much of her time at home with her four                
          children; however, she had some limited involvement in the family           
          real estate business.  Petitioner assisted decedent in book-                
          keeping chores and showed rental properties to prospective                  
          tenants as vacancies arose.                                                 
               In 1984, decedent became involved in a gold mining venture,            
          International Mining Research and Development, Inc. (Interna-               
          tional Mining).  International Mining was a Montana corporation             
          whose purpose was to engage in mining activities.  Petitioner and           
          decedent were among five investors in International Mining.                 
          Petitioner and decedent contributed four subdivided residential             
          lots for a 20-percent stake in International Mining.  Some of the           
          other investors contributed some money to the project; however,             
          others contributed instead their expertise.  International Mining           






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