Bruno and Francesca Tabbi - Page 5

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          spent most of the time after Antonino was born caring for him and           
          petitioners' two older children.  Antonino was in the hospital              
          frequently from September 1988 to April 1990.  He had heart                 
          surgery in April 1990, and was hospitalized until late July.                
          Petitioners were at the hospital with him continuously during               
          these 4 months.  Antonino died 10 days after he was discharged              
          from the hospital.                                                          
          2.   Petitioner Husband's Real Estate Activities                            
               Petitioner husband was a real estate broker from 1974 to               
          1989.  Petitioners owned rental properties and investment real              
          estate in 1987, 1988, and 1989.                                             
               Petitioner husband was also in the business of buying and              
          selling homes through his company, Americana Investment Corp.               
          (Americana).  Because of changes in the Detroit real estate                 
          market in 1986 and 1987, petitioner husband could not sell as               
          many houses in the years in issue as he had previously.                     
          Petitioner husband rented the houses until he could sell them,              
          and made repairs that were necessary to keep the houses in                  
          saleable condition.                                                         
               Petitioner husband conducted his real estate activities                
          through several business entities.  His business operations were            
          disorganized.  He did not keep good records.  He intermingled               
          assets and funds between his many business and personal bank                
          accounts, and he was thinly capitalized and overextended in                 
          credit.  Because of his disorganization and lack of records, he             




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