John F. Daugharty and Sarah R. Daugharty - Page 4

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                                          FINDINGS OF FACT                                               
                  Some of the facts have been stipulated and are so found.                               
            The stipulation of facts is incorporated herein by this                                      
            reference.  Petitioners John F. and Sarah R. Daugharty and                                   
            petitioner Faye E. Daugharty all resided in Jacksonville Beach,                              
            Florida, when they filed their petitions in these cases.1                                    

            Background                                                                                   

                  John and Faye were married on March 20, 1958, in Atlanta,                              
            Georgia.  During their marriage, which lasted over 22 years, John                            
            and Faye had three children, one of whom was a minor when the                                
            marriage dissolved in 1981.                                                                  
                  Following his graduation from the University of Georgia in                             
            1958 with a degree in business administration, John was employed                             
            in credit and financial related capacities and eventually became                             
            manager of General Electric Credit Co.'s finance department,                                 
            where he served until his retirement.                                                        
                  In or around 1965, John and Faye relocated to Jacksonville,                            
            Florida.  On August 13, 1970, John entered into a contract to                                
            purchase the Landon Imperial Apartments for $155,000.  Landon                                
            Imperial Apartments is an 80-unit apartment complex located in                               
            Duval County, Florida.  The contract provided that the seller                                

                  1Petitioner Sarah R. Daugharty is a party to these                                     
            proceedings solely as a consequence of having filed joint returns                            
            with petitioner John F. Daugharty.                                                           




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