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At the time the petitions in the instant case were filed,
petitioner resided in Sarasota County, Florida.
Petitioner was born in The Netherlands on November 14, 1938.
He immigrated to Canada sometime thereafter and became a citizen
of that country. Petitioner was involved in the construction
business in Ontario, Canada, until 1976. Petitioner immigrated
to the United States during that year.
On April 7, 1977, petitioner married Colleen Murphy, and the
marriage continued through the years in issue. Ms. Murphy also
goes by the name "Kelly Murphy". During the years in issue, Ms.
Murphy used the names Colleen Van Heemst and Kelly Van Heemst.
Petitioner and Ms. Murphy were divorced no earlier than April 15,
1991.
In 1978, petitioner started Cape Town Development, Inc.
(Cape Town Development), a corporation that built commercial and
residential properties, of which he was the president and sole
shareholder. The corporation ceased operations, possibly during
1986, and filed for bankruptcy during 1986 or 1987. Ultimately,
petitioner and Ms. Murphy satisfied the claims of Cape Town
Development's creditors because they were guarantors of all debts
incurred by that corporation. Cape Town’s bankruptcy proceeding
was dismissed in 1988. Petitioner did not have a large amount of
assets after that bankruptcy.
During the years in issue, petitioner and Ms. Murphy jointly
owned and operated a sole proprietorship known as “Pieces of
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