Estate of John Kenly, Deceased, Betty B. Kenly, Personal Representative - Page 8

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            married man, dealing with his sole and separate property".  The                               
            title insurance policy covering the 794-acre Bard parcel                                      
            identified the owners of that parcel as "ZONA KENLY, a divorced                               
            woman, and JOHN KENLY, a married man dealing with his sole and                                
            separate property".  In November 1981, petitioner signed a                                    
            quitclaim deed to decedent with respect to the 794-acre Bard                                  
            parcel.  In 1983, petitioner signed a quitclaim deed with respect                             
            to the 80-acre parcel.                                                                        
                  In 1984, Zona Kenly and decedent agreed to lease the 794-                               
            acre Bard parcel to Tanimura & Antle, Inc. (Tanimura & Antle),                                
            from January 1, 1985, to June 30, 1988, for a total rent of                                   
            $754,600.  According to the lease agreement, the lessors were                                 
            “JOHN KENLY and ZONA KENLY, dealing with their sole and separate                              
            Purchase of Additional Parcel of Bard Property                                                
                  In 1986, Zona Kenly and decedent bought an additional                                   
            125 acres of property in Bard, California (the 125-acre Bard                                  
            parcel; the 794-acre Bard parcel and the 125-acre Bard parcel,                                
            together, will be referred to as the Bard property), for                                      
            $440,000.  Before completing the purchase of the 125-acre Bard                                
            parcel, decedent and Zona Kenly made a counteroffer to the                                    
            sellers of that parcel.  That counteroffer identified the                                     
            offerors to include "John Kenly, husband of Betty Kenly, * * *                                
            [dealing with] his sole and separate property, and Zona Kenly, a                              

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